Tax Appeals Outcome: Revenue appeals dismissed, assessee partly successful, case remanded for fresh decisions.

The Revenue's appeals for Assessment Years 2011-12 and 2013-14 were dismissed. The assessee's appeals for Assessment Years 2011-12 and 2012-13 were partly allowed, with certain issues being restored to the CIT(A) and AO for fresh decisions. The Tribunal provided specific directions to ensure the assessee had opportunities to present their case effectively.

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Issues Involved:
1. Disallowance of expenditure claimed under amortization.
2. Provision for privileged leave encashment.
3. Provision for standard assets.
4. Provision for bad and doubtful debts.
5. Bad debts written off.
6. Disallowance of interest paid on bank deposits.
7. Charging of interest under Sections 234B and 234C.

Detailed Analysis:

1. Disallowance of Expenditure Claimed Under Amortization:
The Revenue's appeals for Assessment Years 2011-12 and 2013-14 were dismissed. The Tribunal noted that the CIT(A) had allowed relief to the assessee based on the Tribunal's order in the assessee's own case for Assessment Years 2007-08 and 2009-10. The Revenue did not claim that this Tribunal order was stayed or reversed by the High Court. Therefore, no intervention was called for in the CIT(A)'s order.

2. Provision for Privileged Leave Encashment:
The assessee's appeals for Assessment Years 2011-12 and 2012-13 included a dispute over the disallowance of provision made for privileged leave encashment. The Tribunal found that this issue was covered against the assessee by the judgment of the Hon'ble Apex Court in UOI and Ors Vs. Exide Industries Limited, which upheld the validity of clause (f) in section 43B of the Income Tax Act, 1961. Consequently, this issue was decided against the assessee.

3. Provision for Standard Assets:
The assessee did not press the ground regarding the provision made on standard assets for both Assessment Years 2011-12 and 2012-13. Therefore, this ground was rejected as not pressed.

4. Provision for Bad and Doubtful Debts:
For both Assessment Years 2011-12 and 2012-13, the Tribunal restored the issue regarding the disallowance of provision for bad and doubtful debts to the file of the CIT(A) for a fresh decision. This decision was based on the Tribunal's order in the assessee's own case for Assessment Year 2010-11, where the issue was restored for lack of compliance with Rule 6ABA. The CIT(A) was directed to obtain a remand report from the AO if the assessee filed the required details.

5. Bad Debts Written Off:
The Tribunal did not specifically address this issue in the provided judgment text. It is presumed to be part of the broader issue of provision for bad and doubtful debts.

6. Disallowance of Interest Paid on Bank Deposits:
The issue regarding the disallowance of interest paid on bank deposits under section 40(a)(ia) of the Income Tax Act, 1961, was restored to the AO for a fresh decision. The Tribunal referred to its order in the case of Pragathi Krishna Gramin Bank Vs. ACIT, where it was held that if Form 15G/15H were filed before the respective CIT, even belatedly, the assessee would get the benefit. The AO was directed to verify the availability and submission of these forms.

7. Charging of Interest Under Sections 234B and 234C:
The Tribunal did not specifically address this issue in the provided judgment text.

Conclusion:
The appeals of the Revenue for Assessment Years 2011-12 and 2013-14 were dismissed. The assessee's appeals for Assessment Years 2011-12 and 2012-13 were partly allowed. The Tribunal restored certain issues to the CIT(A) and AO for fresh decisions with specific directions, ensuring that the assessee was afforded adequate opportunities to present their case.

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