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    <title>2025 (2) TMI 1614 - ITAT PUNE</title>
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    <description>Interest on non-performing assets of a co-operative bank governed by RBI prudential norms is recognised on receipt basis, not on accrual basis, even where mercantile accounting is followed, so notional NPA interest is not taxable merely because it is reflected in the books. A provision for robbery and fraud losses may be deductible as an ascertained business liability where the loss has crystallised from identified incidents and supporting facts show it is not contingent. Where the crystallisation of a fraud provision is not clearly established, the matter requires fresh verification before deduction is allowed. Interest charged by RBI for shortfall in CRR and SLR maintenance is treated as compensatory business expenditure, not a penalty.</description>
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      <description>Interest on non-performing assets of a co-operative bank governed by RBI prudential norms is recognised on receipt basis, not on accrual basis, even where mercantile accounting is followed, so notional NPA interest is not taxable merely because it is reflected in the books. A provision for robbery and fraud losses may be deductible as an ascertained business liability where the loss has crystallised from identified incidents and supporting facts show it is not contingent. Where the crystallisation of a fraud provision is not clearly established, the matter requires fresh verification before deduction is allowed. Interest charged by RBI for shortfall in CRR and SLR maintenance is treated as compensatory business expenditure, not a penalty.</description>
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