Federal Bank Ltd. v. DCIT (2019) 417 ITR 694/( 2020) 269 Taxman 190 (Ker)(HC)

S. 36(1)(viia) :Bad debt-Provision for bad and doubtful debts – Schedule bank -Bad debts written off in accounts is deductible – Determination of Rural branch is to be based on revenue records .

Court held that the assessee had actually written off the amounts. In such circumstances, it is only proper that the Assessing Officer verify the balance-sheet of the assessee, produced for the year and decide the question of deduction under section 36(1)(vii) . Followed Vijay Bank v. CIT ( 2010) 323 ITR 166 (SC)  For  the determination of non-rural branches shall be only with reference to the revenue villages and not solely on the basis of population in an area as demarcated by the assessee-bank. The Assessing Officer rightly computed 10 per cent. of the aggregate advances at Rs. 3,27,15,858. Thus, a total amount of Rs. 45,30,81,080 was arrived at as eligible for deduction. (AY.2006 -07)