DCIT Vs Jila Sahakari Kendriya Bank Maryadit (ITAT Raipur)
The appeal before the Income Tax Appellate Tribunal (ITAT), Raipur, was filed by the Revenue against the order of the Commissioner of Income Tax (Appeals), NFAC, Delhi dated 21.10.2024 for Assessment Year 2014–15. The dispute arose from reassessment proceedings initiated under sections 147 and 144 of the Income Tax Act, 1961, wherein the Assessing Officer (AO) made multiple additions, including an addition of ₹17 crore on account of alleged double deduction of provision for bad and doubtful debts.
The assessee, a co-operative society, had originally filed its return declaring total income of ₹9.62 crore, which was assessed at ₹12.70 crore under section 143(3). Subsequently, the case was reopened, and reassessment resulted in further additions, including ₹17 crore for alleged double deduction of bad debts, ₹1.5 crore disallowance towards contribution to Society Cadre Fund under section 37, and ₹26.72 lakh disallowance under section 36(1)(va), raising the assessed income to ₹31.47 crore.
On appeal, the CIT(A) examined the records and found that the assessee had already added back ₹21.66 crore in its computation of income under Schedule BP, which included the ₹17 crore provision for bad and doubtful debts. It was held that the assessee had not claimed double deduction, as the provision was already disallowed in the computation. Accordingly, the CIT(A) deleted the ₹17 crore addition made by the AO.
