9911796707
TMI Blog2015 (1) TMI 297X X X X Extracts X X X X X X X X Extracts X X X X ..... th the amount in the audited P 16.91 crores in the return - There is no evidence anywhere in the record from which it can be ascertained as to how the figure of 16.91 crores has been arrived at by the AO - Revenue has not pointed out any error in the facts recorded by the CIT(A) in the order – the order of the CIT(A) is upheld – Decided against revenue. X X X X Extracts X X X X X X X X Extracts X X X X ..... the amounts as both were same. 4. Having considered the rival submissions and careful perusal, we note that the ld. CIT (A) has considered the reconciliation of the amounts shown in the NPA return with the RBI as well as annual accounts and return of income and found that the figure tallied with the amount in the audited P&L account and balance sheet. The finding of the ld. CIT (A) discussing all the facts is in paragraphs 5 to 7 which are reproduced as under: "5. In order to ascertain the basis of the addition, the Assessing Officer was requested vide this office letter dtd. 26th July, 2012 to provide a copy of the NPA return based on which it is concluded by the Assessing Officer that bad debts disclosed by the assessee is ₹ ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... vision and taxes as per RBI NPA return Rs.123,330 Lakhs (as 2 Net profit as per accounts Rs.57,163 lakhs (as per annual report III) 3 Add: Prov. And Contingencies Rs.66,167 lakhs (as per Schedule Total Earnings as per Accounts Rs.123,330 lakhs (as per annual report) Reconciliation of Other Advances: Provision on standard Advances (-) ₹ 900 lakhs (as per RBI return) Provision for other assets (-) ₹ 900 lakhs (Schedule 17, II. As per annual report) Reconciliation of the Total NPA as per RBI return and as per Accounts: 3(a) Total NPA as per RBI return Non-performing loans and advances Rs.7,848 lakhs Bad and doubtful debts Rs.8,658 lakhs Total Rs.16.506 Lakhs 3(b) Total NPA as per accounts Provisions for no ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... sum of ₹ 1,560,552,159 (i.e. Provision for non-performing assets / write offs ₹ 1,650,552 Less Reversal of Provision for other assets ₹ 90,000,000) has been added back in computing the total taxable income. e. Claim has been made forbad debts of ₹ 513, 134,359 (refer page 40 of the paper book), after setting off the opening balance of ₹ 352,641,221 under section 36(1)(viia). The computation of the claim for bad debts was enclosed with the return of income for the A Y 2004-05. The above figures were tallied by the assessee with the figures in the audited P&L accounts and balance sheet. It was hence submitted that the claim of the assessee on account of bad debts is duly supported by its P&L account and balance ..... X X X X Extracts X X X X X X X X Extracts X X X X
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