Taxpayer Can Choose Between Sections 36(1)(vii) and 36(1)(viia) for NPA Loan Deductions; Section 36(2) Conditions Unclear.

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....Disallowance on account of Principal NPA - Time Barred Interest on over-due NPA loan accounts - To avoid the double deduction, the proviso to section 36(1)(vii ) was inserted and the assessee has choice to choose between 36(1)(vii) and 36(1)(viia) whichever is beneficial. The finding of the LD. CIT (A) are not based on the complete details as to whether this amount on account of Time Barred Interest on NPA loans is fully satisfied the condition of section 36(2). - AT....