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Before us, the Ld. counsels for the appellant submit that in its annual accounts for the financial year (FY) ending 31.03.1997, the assessee debited an amount of Rs. 833,30,47,694/- to its P&L account as provision for bad and doubtful debts and the same amount was admittedly also reduced from the loans and advances as appearing in the balance sheet and the net amount of such loans and advances was reflected in the balance sheet. Referring to the decision inVijaya Bank(supra), it is stated that such treatment in the accounts is to be regarded as 'write off' which would qualify for deduction u/s 36(1)(vii) of the Act.

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Section 36(1)(vii) of the Income Tax Act, 1961— Business Expenditure — Bad debts — Assessee was entitled to deduction under section 36(1)(iii) as assessee bank made provisions for bad debts in its books by way of debit to profit and loss account and also reduces said amount from loans and advances as appearing on asset side on balance sheet— State Bank of India vs. Principal Commissioner of income tax [2019] 179 ITD 764 (Mumbai)

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