Provisions for NPA as per RBI Norms by NBFCs not deductible

The assessee, a NBFC, made a ‘Provision for NPA’ in terms of the RBI Directions 1998. It claimed a deduction for the said provision u/s 36 (1)(vii) on the ground that as it was debited to the P&L Account and reduced the profits, it was a ‘write off’. In the alternative, it was claimed that there was a diminution in the value of its assets for which a deduction u/s 37 as a trading loss was eligible. It was also claimed that the RBI Directions overrode the I. T. Act. The Tribunal allowed the claim but the High Court rejected it. On appeal, HELD dismissing the claim: (i) The RBI Direc...