2019 (5) TMI 29

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....ed that the assessee is engaged in banking business. Return for the year under consideration was filed declaring total income at NIL, inter alia, claiming deduction u/s. 36(1)(viia) of the Act amounting to Rs. 122,56,95,246/-. During the course of assessment proceedings, the assessee filed a revised return reducing its amount of deduction u/s.36(1)(viia) to Rs. 25,21,93,0828/-, being the amount of provision for bad and doubtful debts as per the books of account. The Assessing Officer did not accept the revised return. He, however, completed the assessment making addition of Rs. 97,35,02,163/-, being the amount of excess deduction originally claimed by the assessee in the return of income but given up in the revised return. The ld. CIT(A)....

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....he aggregate average of rural advances made by the rural branches of the bank as against the lower amount of provision created in the books of account, the Chairman submitted that : "As suggested by the Central Statutory Auditor, Jhodh and Joshi and Company, the bank has claimed deduction u/s.36(1)(viia) of Rs. 122,56,95,246/- against the provision for bad and doubtful debts against NPA advances while filing our income tax return". He further stated that actual provision for bad and doubtful debts made in the books of account was only to the tune of Rs. 25.21 crore. He still further explained that "at the time of filing of income-tax return, there were thoughts before the bank to claim the deduction to the extent of 7.5% of profit ......as ....