Proviso to section 36(1)(vii) cannot be applied for disallowing deduction claimed on bad debts relating to non-rural advances

Canara Bank Vs DCIT (ITAT Bangalore) ITAT Bangalore held that when the proviso to section 36(1)(vii) applies to bad debts written off relating to rural advances, the same cannot be applied for disallowing deduction claimed on account of write off of bad and doubtful debts relating to nonrural/urban advances. Facts- For AY 2011-12, the AO noted that the assessee had claimed deduction of bad debts under Section 36(1)(vii) Income Tax Act without actually writing off the debts as irrecoverable in the individual loan accounts of the debtors concerned. The AO found that majority of the write-off was...