State Govt Undertaking Faces Tax Scrutiny: Guarantee Commission Disallowed and Debt Provisions Remanded for Detailed Review

ITAT adjudicated two key tax issues involving a State Government undertaking. First, the tribunal upheld disallowance of guarantee commission paid to Kerala State Government under section 40(a)(iib), aligning with Supreme Court precedent that fees paid by State Government undertakings are non-deductible. Second, regarding provision for bad and doubtful debts, the tribunal remanded the matter to the Assessing Officer for reconsideration, directing a detailed examination of debt write-offs consistent with Supreme Court guidelines in Vijaya Bank case. The first ground was dismissed, while the second ground was partly allowed for statistical purposes, mandating a fresh assessment of deductibility criteria. .....

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