2021 (6) TMI 597

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....irupati is erroneous and is not based on facts and circumstances of the case and the weight of the evidence placed before the Ld. CIT(Appeals), 2. The Ld. CIT (Appeals), Tirupati, erred in stating that the appellant has not controverted the finding of the AO that there is no debit towards "Provision for doubtful debts" 3. The Ld. CIT (Appeals), Tirupati erred in understanding the fact that the appellant fully complied with the Provisions of Sec 36(1)(viia) and hence is eligible for deduction of Provision for bad and doubtful debts. 4. The Ld. CIT (Appeals), Tirupati erred in upholding the Order of the Ld. AO, who made failed to understand the distinction between the words "Provision" and "Reserve" 5. The Ld. CIT (Appeals), Tirupati ....

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....,887/-. 3. When the assessee preferred an appeal before the CIT(A), the CIT(A) confirmed the order of the AO. 4. Aggrieved the assessee is in appeal before the ITAT. 5. Before us, the ld. AR of the assessee filed a paper book containing written submissions, revised return filed along with computation, original return of income filed along with computation, audited financial statements and perpetual debt instrument issued by Vasavi Coop Urbank Bank. In the written submissions, the assessee stated that since there is a debit to the profit and loss account in respect of provision for doubtful debts and since, the same is below the limit of 78.50% of total income, the assessee is entitled to deduction of Rs. 12,74,887/- u/s 36(1)(viia). Furt....