2025 (11) TMI 638

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....es from the assessment order dated 28.09.2021 passed u/s 147 r.w.s. 144 of the Act by Assessment Unit, Income Tax Department, NFAC, Delhi (in short "Ld. AO"). 2. The grounds of appeal raised by the revenue are as under: 1. Whether on the facts and in the circumstances of the case, the ld. CIT(A) was justified in deleting the addition of Rs. 17,00,00,000/- made by the AO on account of wrong claim of deduction of provision for bad/doubtful debt? 2. The order of ld. CIT(A) is not accordance with laws and facts of the case. 3. Any other ground which may be adduced at the time of hearing. 3. Brief facts of the case are that the assessee is a Co-operative Society, had filed its return of income for the assessment ....

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....r, grounds of appeal and submission of the appellant carefully. The appellant contended that the it has not claimed the deduction twice but the amount of 21.64 crores was already added back in the computation of income which includes the provision of bad debts Rs. 17,00,00,000/- . I have verified the contention of the appellant from the return of income and found that an amount of Rs. 21,66,46,812/- is added back as per column No. 24 under schedule BP(A). Thus the contention of the appellant is found to be correct. Hence the addition made by the AO of Rs. 17,00,00,000/- is hereby deleted and the ground of appeal raised by the appellant is allowed. 5. Since aforesaid relief was granted to the assessee by Ld. CIT(A), being aggrieved, the r....

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....der misreading of the facts, thus, the same cannot be sustained. 8. We have considered the rival submissions, and perused the material available on record, including the verification of facts and documents on record. We found that the assessee had added the amount of provisions of bad and doubtful debts for Rs. 17,00,00,000/- to its taxable income in computation for the relevant year, therefore, it was just a misconception of Ld. AO that assessee had claimed such amount twice first in P&L and thereafter in computation. Such misunderstanding of Ld. AO was correctly observed by Ld. CIT(A) after verifying the facts from records and has therefore rightly deleted the addition. We find substance in the finding of Ld. CIT(A) that the assessee h....