Eligibility for Bad Debt Deduction Hinges on Banking License Verification per Section 36(1)(viia), Says AO.

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....Disallowance of bad debts as claimed u/s 36(1)(viia) - deduction claimed @10% of aggregate average advances - AO is directed to make relevant enquires and verifications , including , inter-alia, making enquiries from RBI to seek relevant information to arrive at decision whether the assessee will be eligible for deduction u/s 36(1)(viia). Thus , if it is found by AO after due verifications and enquiries that the assessee was granted banking license by RBI which covers relevant previous year 2009-10, then in our view the assessee will be eligible for deduction u/s 36(1)(viia) under both the limbs. - AT....