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The Dakshin Dinajpur District Central Co-operative Bank Ltd. Vs. DCIT, Circle 3

Case No: ITA Nos. 2187 to 2189/KOL/2025
Court: Income Tax Appellate Tribunal 'A' Bench, Kolkata
Date: 2/10/2026

Parties Involved

AppellantThe Dakshin Dinajpur District Central Co-operative Bank Ltd.
RespondentDCIT, Circle 3

Facts Summary

The Assessing Officer (AO) disallowed expenses amounting to ₹1,78,019/- at the rate of 10% of the total miscellaneous expenses of ₹17,80,192/- on the grounds that these expenses were represented by self-made vouchers and were not verifiable. The assessee claimed these expenses were composite expenses of 7 branches for day-to-day operations. In another issue, the AO disallowed provisions for non-performing assets (NPA) amounting to ₹2,72,91,922/- under the head 'other expenses', despite the assessee's claim that these provisions were in accordance with RBI and NABARD guidelines and allowable under Section 36(1)(viia) of the Act.

Decision in favour of

Assessee

Legal Issues

  • 1. Disallowance of ₹1,78,019/- as 10% of miscellaneous expenses.
  • 2. Disallowance of ₹2,72,91,922/- as provisions for NPA.

Judgment Outcome

Decided in favour of Assessee.

Precedents Relied Upon

5 precedents cited in this judgement.

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