City Union Bank Ltd. v. ACIT (2019) 74 ITR 644 (Chennai)(Trib. )

S. 36(1)(vii) : Bad debt–Provisions for bad and doubtful debts-Reduced from advance account in the balance sheet allowable as deduction to the extent of write off. [S. 36(1)(viia)]

Allowing the appeal of the assessee the Tribunal held that CIT(A) erred in combining the provisions of S.  36(1)(vii) and S.  36(1)(viia).  Tribunal observed that CIT(A) considered only the provisions of bad and doubtful debts debited to profit and loss account and ignored the write off of bad debts debited to provisions for bad and doubtful debts and reduced from advance from the Balance Sheet which also constitutes  write off.  Accordingly, Tribunal remanded the issue back to the file of the AO for limited purpose of verifying the amount of write off debited to provisions of bad and doubtful debts and reduced from advance account in the balance sheet and allow the same as deduction to the extent of write off.  (AY.  2012-13,  2014-15)