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TMI Blog2019 (7) TMI 1973X X X X Extracts X X X X X X X X Extracts X X X X ..... al filed by the assessee. The relevant assessment year is 2014-15. The appeal is directed against the order of the Commissioner of Income Tax-3, Mumbai [in short 'CIT(A)'] and arises out of the assessment completed u/s 143(3) of the Income Tax Act 1961, (the 'Act'). 2. The ground of appeal filed by the assessee reads as under: 1. The Ld. CIT(A) erred in law and facts in disallowing deduction of ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ision for doubtful debts created by the assessee is only Rs.60,00,000/- and accordingly, the deduction u/s 36(1)(viia) is required to be restricted to Rs.60,00,000/-. Thus the AO disallowed the excess claim of deduction of Rs.8,86,815/-. In appeal, the Ld. CIT(A) agreed with the reasons given by the AO and confirmed the above disallowance. 4. Before us, the Ld. counsel of the assessee submits th ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... of the provision have to be given as per the direction of the RBI Circular. It is stated that the assessee has created a provision for bad and doubtful debts which may be under different nomenclature but this will not disentitle the assessee for claiming deduction under provisions of section 36(1)(viia) of the Act. In this regard, reliance is placed by him on the order by (i) ITAT Amritsar Bench i ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ely allows deduction in respect of provision for bad and doubtful debts to the extent mentioned in the various clauses of sub-section (1) of section 36 of the Act. The deduction under section 36(1)(viia) of the Act is allowed only in respect of certain specific categories of assessee mentioned in the clause like banks, financial institutions, etc. who are in business of lending money. It is not al ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... als with further deduction for provisions on bad and doubtful debts. The claim of the assessee is covered in the main provisions of section 36(1)(viia) of the Act." Similar is the decision in M/s Punjab Gramin Bank (supra). 5.1 In Vellore District Central Co-operative Bank Ltd. (supra), it is held by the Tribunal that doubtful debts may be under different nomenclature and this will not disent ..... X X X X Extracts X X X X X X X X Extracts X X X X
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