Political contribution deductions require recipient party compliance with contribution-reporting conditions; banking-channel donations alone do not qu...
Aggregation under TNMM prevents selective testing of intra-group services without comparable uncontrolled transactions, while appellate additional cla...
Protective assessment cannot duplicate identical receipts under competing characterisations; remote services did not establish a taxable permanent est...
Current account treatment of overseas tournament services removed most FEMA findings, but excess EEFC remittance and delayed repatriation remained bre...
Modification of bail conditions remains available through inherent jurisdiction where onerous deposits undermine justice and cannot recover disputed d...
Merchant banker regulation consolidates registration, governance, capital, reporting, outsourcing and investor-protection requirements under an update...
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Section 36(1)(viia) allows deduction only for a provision for bad and doubtful debts actually made in the bank's books and within the statutory ceiling linked to total income and average rural advances. For the years in question, the provision need not follow any separate Income-tax Act method of quantification, and RBI prudential norms govern provisioning, including a general provision on standard assets because they still carry credit risk. The earlier proviso relating to doubtful or loss assets was confined to specified earlier assessment years and did not exclude standard assets here. The Special Bench answered the reference for the assessee and held that provision on standard assets made in accordance with RBI norms qualified for deduction, subject to the books and ceiling requirements.
Section 36(1)(viia) allows deduction only for a provision for bad and doubtful debts actually made in the bank's books and within the statutory ceiling linked to total income and average rural advances. For the years in question, the provision need not follow any separate Income-tax Act method of quantification, and RBI prudential norms govern provisioning, including a general provision on standard assets because they still carry credit risk. The earlier proviso relating to doubtful or loss assets was confined to specified earlier assessment years and did not exclude standard assets here. The Special Bench answered the reference for the assessee and held that provision on standard assets made in accordance with RBI norms qualified for deduction, subject to the books and ceiling requirements.
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