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TMI Blog2021 (6) TMI 597X X X X Extracts X X X X X X X X Extracts X X X X ..... s made for bad debts in P L Account. It is clear from the order of the CIT(A) that in the revised Profit Loss Account, the disputed issue was debited in the Profit Loss Account. Therefore, following the ratio laid down by the Hon ble Court, we set aside the order of the CIT(A) and direct the AO to allow the assessee s claim of the provision for bad and doubtful debts - Appeal of the assessee is allowed. - ITA No. 659/H/2019 (Assessment Year: 2015-16) - - - Dated:- 19-4-2021 - SHRI SATBEER SINGH GODARA, JUDICIAL MEMBER AND SHRI LAXMI PRASAD SAHU, ACCOUNTANT MEMBER Assessee by: Shri E. Phalguna Kumar Revenue by: Shri Sunil Kumar Pandey ORDER PER LAXMI PRASAD SAHU, A.M.: This assessee s appeal for AY 2015- ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ected for scrutiny under CASS and accordingly statutory notices were issued to the assessee, against which, the assessee filed the information. 2.1 During the course of scrutiny assessment proceedings, the Assessee filed its statement of income, profit and loss account and audit report etc., on perusal of which, the AO noticed that the assessee admitted an income of ₹ 1,59,94,405/- and from the same claimed deduction u/s 36(1)(vii)(a) at ₹ 2,88,23,764/-, which was restricted to ₹ 1,59,93,405/-. When asked to show cause, the assessee filed revised return of income on 14/12/2017 and admitted an income of ₹ 1,57,23,600/- and the claim made at ₹ 2,76,24,259/- towards average advances made in rural branch was wit ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... f ₹ 12,74,887/- u/s 36(1)(viia). 6. The ld. CIT-DR, on the other hand, relied on the orders of revenue authorities. 7. We have considered the rival submissions and perused the material on record as well as gone through the orders of revenue authorities. The fact that the assessee filed the revised return of income by claiming provision for bad and doubtful debts. There is no doubt that the assessee is engaged in the business of banking and has made provision for bad and doubtful debts for loans and advances. The AO doubted whether it was a reserve or provision. But, the assessee in the second revised computation of income in the profit loss account, it changed as provision in place of reserve . The contention of the assesse ..... X X X X Extracts X X X X X X X X Extracts X X X X
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