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    <title>2014 (1) TMI 945 - ITAT CHENNAI</title>
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    <description>Section 36(1)(viia)(a) extends the deduction for provision for bad and doubtful debts to a co-operative bank, apart from a primary agricultural credit society or a primary co-operative agricultural and rural development bank, and a co-operative bank carrying on banking activity was treated as within that framework. A reserve described as &quot;Reserve for NPA&quot; satisfied the statutory requirement because substance prevailed over accounting nomenclature, and the reserve served the same purpose as a provision for bad and doubtful debts. In light of both findings, the assessment could not be said to be erroneous and prejudicial to the Revenue, so revision under section 263 failed and the assessment was restored.</description>
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      <title>2014 (1) TMI 945 - ITAT CHENNAI</title>
      <link>https://www.taxtmi.com/caselaws?id=242729</link>
      <description>Section 36(1)(viia)(a) extends the deduction for provision for bad and doubtful debts to a co-operative bank, apart from a primary agricultural credit society or a primary co-operative agricultural and rural development bank, and a co-operative bank carrying on banking activity was treated as within that framework. A reserve described as &quot;Reserve for NPA&quot; satisfied the statutory requirement because substance prevailed over accounting nomenclature, and the reserve served the same purpose as a provision for bad and doubtful debts. In light of both findings, the assessment could not be said to be erroneous and prejudicial to the Revenue, so revision under section 263 failed and the assessment was restored.</description>
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