DCIT v. Syndicate Bank (2022) 291 Taxman 166 (Karn) (HC)

S. 36(1)(viia) : Bad debt-Provision for bad and doubtful debts-Schedule bank-Deduction to be computed at rate of 7.5 per cent of total income-After setting off of brought forward losses. [S. 36(vii), 72]

Allowing the review petition filed by the Revenue, the High Court held that it is a settled law that deduction towards bad and doubtful debts at 7.5% shall be made after setting off the brought forward loss, to arrive at the total income. Hence, the judgment passed by this Court is modified and the substantial question framed is answered in favour of Revenue.