2018 (9) TMI 224

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....ch bad and doubtful debts. On facts, it has to be noticed that as evident from the assessment order, there are two components insofar as the assessee is concerned, one is urban and the other is rural. With respect to the urban branches, the claim made by the assessee was more than Rs. 115 crores as having been written off in the previous year to the assessment year, as bad debts. There was a provision made in the earlier year under Section 36(1)(viia) of the Income Tax Act (for brevity "the Act") of Rs. 45 lakhs. The Assessing Officer reduced the claim to the extent of the provision and granted deduction of Rs. 70 crores. The First Appellate Authority reversed the same and granted the entire claim. The revenue filed an appeal before the Tri....

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....d fact in upholding the action of the authorities below in refusing the claim of the appellant for write off bad debts relating to rural branches amounting to Rs. 24, 53, 972/-? B. Is not the finding of the Tribunal a perverse finding on facts due to non-consideration of relevant facts and one based on surmises and conjectures?" 3. The decision in Catholic Syrian Bank Ltd's case (supra) was on the question whether the deduction on account of provision under Section 36(1)(vii) is independent of the deduction on account of provision under Section 36(1)(viia) of the Act. The Assessing Officer in the said case had directed the deduction claimed under Section 36(1) (vii) to be adjusted as against the provision of bad and doubtful debts ....