https://www.taxtmi.com/caselaws?id=765405 ITAT Surat dismissed appellant's claim for deduction under section 36(1)(viia) for bad and doubtful debt reserve, distinguishing between "reserve" and "provision" - holding that reserve represents assessee's own funds while provision constitutes liability, making them non-equivalent for deduction purposes. However, ITAT partly allowed appellant's alternate claim regarding write-off of fixed deposits with MMCB, ruling that such deposits formed part of banking business stock-in-trade rather than capital assets, and their write-off following RBI license cancellation constituted allowable business loss, directing AO to delete the addition. en-us Thu, 05 Dec 2024 00:00:00 +0530 Fri, 31 Jan 2025 07:54:27 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=765405 ITAT Surat dismissed appellant's claim for deduction under section 36(1)(viia) for bad and doubtful debt reserve, distinguishing between "reserve" and "provision" - holding that reserve represents assessee's own funds while provision constitutes liability, making them non-equivalent for deduction purposes. However, ITAT partly allowed appellant's alternate claim regarding write-off of fixed deposits with MMCB, ruling that such deposits formed part of banking business stock-in-trade rather than capital assets, and their write-off following RBI license cancellation constituted allowable business loss, directing AO to delete the addition. Case-Laws Income Tax Thu, 05 Dec 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=765405