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Case lawITAT › The Karnataka Bank Ltd v DCIT (ITAT Bangalore) — Explanation 2 to s.36(1)(vii) brings in the clause (b) to (d) assessees; it does not make a clause (a) bank set its non-rural write-off against the rural provision
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The Karnataka Bank Ltd v DCIT (ITAT Bangalore) — Explanation 2 to s.36(1)(vii) brings in the clause (b) to (d) assessees; it does not make a clause (a) bank set its non-rural write-off against the rural provision

For assessment year 2014-15 onwards the Assessing Officer says Explanation 2 to s.36(1)(vii) requires my client bank to set its NON-RURAL bad debts against the s.36(1)(viia) provision account before claiming anything. Is that right?

For assessment year 2014-15 onwards the Assessing Officer says Explanation 2 to s.36(1)(vii) requires my client bank to set its NON-RURAL bad debts against the s.36(1)(viia) provision account before claiming anything. Is that right?

The Bangalore Tribunal held it is not right for a bank claiming under sub-clause (a) of s.36(1)(viia). It construed Explanation 2, inserted by the Finance Act 2013 with effect from 1 April 2014, as operating in respect of sub-clause (a) only in relation to rural advances, and in respect of sub-clauses (b) to (d) — a foreign-incorporated bank, a public financial institution or State financial corporation or State industrial investment corporation, and a non-banking financial company — for advances given by both rural and non-rural branches. Its reason was that the Supreme Court in Catholic Syrian Bank had held sub-clause (viia)(a) to apply to rural advances only, that Parliament did not amend sub-clause (a), and that an Explanation inserted in clause (vii) does not override that construction. It therefore directed the Assessing Officer to allow the bad debts relating to non-rural branches under s.36(1)(vii) without adjusting them against the provision account.

Decided by the ITAT (Shri N.V. Vasudevan, Vice President and Shri B.R. Baskaran, Accountant Member (Income Tax Appellate Tribunal, Bengaluru 'A' Bench)) on 2022-05-26, reported as ITA No. 1907/Bang/2018 and ITA No. 230/Pan/2018, assessment year 2014-15; date of hearing 22 March 2022, date of pronouncement 26 May 2022; no law-report citation is printed on the document read. It bears on section 36(1)(vii), section 36(1)(viia), section 36(1)(viia)(a), section 36(2)(v), section Rule 6ABA, section 14A, section Rule 8D of the Income Tax Act 1961, in Deductions & Disallowances, How Tax Law Is Read and Appeals matters.

Validity check could not be completed. Validity check could not be completed. I did not search for any appeal from this order or for later High Court or Supreme Court treatment of it, and I do not know whether the Revenue took it to the Karnataka High Court. What is established is the Tribunal's own reasoning and disposal, read in full, with the operative direction confirmed on a second, independent retrieval. The label the output vocabulary would tempt one to use — "high courts differ" — is wrong here: the disagreement is between a Tribunal's construction and the construction the Revenue advances on the strength of a Finance Bill Memorandum and a CBDT Explanatory Note, and no conflicting High Court decision was located. A practitioner should treat the point as contested and not as settled. A later Tribunal decision goes the other way on the same question and must be read with this order. In Union Bank of India (Erstwhile Andhra Bank), Hyderabad v. DCIT, Circle-1(1), Hyderabad, ITA No. 193/Hyd/2019 and ITA No. 316/Hyd/2019, assessment year 2015-16, the Hyderabad 'B' Bench (Shri Vijay Pal Rao, Vice President and Shri Madhusudan Sawdia, Accountant Member) held on 21 April 2025, at its paragraph 15.4, that the assessee's 'reliance … on Catholic Syrian Bank Ltd. is misplaced' because in that case no deduction had been claimed under clause (viia) on account of non-rural advances, whereas the bank before it had claimed the clause (viia) provision for non-rural advances and then sought the write-off of the same non-rural debts under clause (vii), which 'results in an impermissible double benefit'; it concluded that the claim under section 36(1)(vii) 'without setting off the inadmissible provision created for non-rural advances, cannot be sustained' (indiankanoon.org/doc/29676534/, read in the original). The two orders are reconcilable on their facts — the Hyderabad bench's route turns on the bank having created its clause (viia) provision in respect of non-rural advances as well — but the outcome is the opposite, it is three years later, and the point must be put to any client relying on Karnataka Bank. The status therefore remains 'unverified': this is contested between Tribunal benches, and no High Court decision either way was located on this pass.

Why it matters

This is the live front line in bank assessments for assessment year 2014-15 onwards, and the practitioner must know exactly what the Tribunal did and did not decide. What it decided: that the words "all types of advances, including advances made by rural branches" in Explanation 2 do their work on the assessees who have no rural branches at all — foreign banks, public financial institutions, State financial corporations, State industrial investment corporations and NBFCs — who could otherwise have used Catholic Syrian Bank to say their write-offs were of "non-rural" debts and so outside the proviso. Its reasoning is that if Parliament had wanted to undo the Supreme Court's construction of sub-clause (viia)(a) it had to amend sub-clause (a) itself, and it did not. What it did not decide: this is a Tribunal, and the Revenue's contrary construction — squarely recorded in the Memorandum explaining the Finance Bill 2013 and in CBDT's Explanatory Note of 24 January 2014, both reproduced in the order, which say the provision account "applies to all types of advances, whether rural or other advances" and that the deduction is limited "without any distinction between rural advances and other advances" — is not displaced by anything higher. A practitioner should take this order as the best available answer for a clause (a) bank, expect the Revenue to press the Memorandum, and be candid with the client that the point is not closed. Note too the second, independently useful holding in the same order: on the Revenue's appeal the Tribunal held that the ten per cent rural limb under Rule 6ABA is worked out on the ENTIRE outstanding advances of the rural branches month by month, not on incremental or fresh advances only. Do not carry this order alone. The Hyderabad Bench of the Tribunal reached the opposite result on 21 April 2025 in Union Bank of India (Erstwhile Andhra Bank) v. DCIT (ITA No. 193/Hyd/2019), holding that where the bank has created its clause (viia) provision in respect of non-rural advances too, the write-off of those same non-rural debts under clause (vii) is an impermissible double benefit. Before relying on Karnataka Bank, establish on the client's own accounts whether the provision claimed under sub-clause (a) was confined to rural advances; if it was not, the Hyderabad reasoning bites.

Binding on the AO and CIT(A) within the Tribunal's jurisdiction. Persuasive elsewhere.

Not yet CA-verified. This entry was found through the sources listed under the Sources tab, and the summary reflects what those sources say. Nobody has yet read the full judgment and signed it off. Check the source before relying on it.

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