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    <title>2017 (11) TMI 1645 - ITAT VISAKHAPATNAM</title>
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    <description>Section 46 of the Andhra Pradesh Co-operative Societies Act, 1964 was treated as an investment-and-application provision, not a diversion of income by overriding title, so the statutory reserve was not deductible on that basis. Recovery-related sundry debtor items were accepted as deductible business outgoings linked to bad and doubtful debts, but interest subsidy receivable from the Government was not a bad debt because the liability had not crystallised as irrecoverable. Waiver of penal interest and interest on overdue deposits was allowed as a business loss, while the NPA provision and contribution to the co-operative educational fund were also allowed as deductions. The overdue interest issue required fresh verification.</description>
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      <description>Section 46 of the Andhra Pradesh Co-operative Societies Act, 1964 was treated as an investment-and-application provision, not a diversion of income by overriding title, so the statutory reserve was not deductible on that basis. Recovery-related sundry debtor items were accepted as deductible business outgoings linked to bad and doubtful debts, but interest subsidy receivable from the Government was not a bad debt because the liability had not crystallised as irrecoverable. Waiver of penal interest and interest on overdue deposits was allowed as a business loss, while the NPA provision and contribution to the co-operative educational fund were also allowed as deductions. The overdue interest issue required fresh verification.</description>
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