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    <title>2021 (11) TMI 522 - ITAT ALLAHABAD</title>
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    <description>Section 36(1)(viia) was discussed as extended to co-operative banks after the 2007 amendment, with eligibility and quantum depending on the banking licence position, the applicable banking-law framework, and proof of aggregate average advances of rural branches under the relevant computation rules. The matter required factual verification by the Assessing Officer, so the deduction claim was remanded for fresh examination on facts and law. On depreciation under section 32, the claim failed because the assessee did not satisfactorily prove purchase, existence, and use of the assets, and depreciation had been claimed at the full rate despite use for less than 180 days; the statutory restriction to fifty per cent was applied and the disallowance sustained.</description>
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      <description>Section 36(1)(viia) was discussed as extended to co-operative banks after the 2007 amendment, with eligibility and quantum depending on the banking licence position, the applicable banking-law framework, and proof of aggregate average advances of rural branches under the relevant computation rules. The matter required factual verification by the Assessing Officer, so the deduction claim was remanded for fresh examination on facts and law. On depreciation under section 32, the claim failed because the assessee did not satisfactorily prove purchase, existence, and use of the assets, and depreciation had been claimed at the full rate despite use for less than 180 days; the statutory restriction to fifty per cent was applied and the disallowance sustained.</description>
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