Dismissing the appeal of the revenue the Court held that , burden is revenue to prove that excess provision for bad and doubtful debt written back in profit and loss account was allowed as deduction in previous years . Accordingly the -deletion of addition is held to be justified .( AY.2008 -09)
CIT v. Pragathi Gramina Bank ( 2018) 91 taxmann.com 343 ( Karn) (HC) Editorial: SLP of revenue is dismissed , CIT v. Pragathi Gramina Bank ( 2018) 259 Taxman 219 ( SC)
S. 41(1) : Profits chargeable to tax – Remission or cessation of trading liability – Provision for doubtful debt- Burden is revenue to prove that excess provision for bad and doubtful debt written back in profit and loss account was allowed as deduction in previous years -Deletion of addition is held to be justified [ S. 36(1)(viia) ]