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Case lawCBDT Circulars & Instructions › Statutory position — the proviso to s.36(1)(vii), s.36(2)(v) and Explanation 2: how a bank's bad-debt write-off is set against the s.36(1)(viia) provision account
CBDT Circulars & InstructionsCuts both wayss.36(1)(vii)s.36(1)(viia)s.36(2)s.36(2)(v)s.145(2)

Statutory position — the proviso to s.36(1)(vii), s.36(2)(v) and Explanation 2: how a bank's bad-debt write-off is set against the s.36(1)(viia) provision account

My client bank has claimed under s.36(1)(viia) and has also written off bad debts. The Assessing Officer says the write-off must first be set against the provision account and only the excess is deductible. Where does that come from, and does it reach non-rural debts?

My client bank has claimed under s.36(1)(viia) and has also written off bad debts. The Assessing Officer says the write-off must first be set against the provision account and only the excess is deductible. Where does that come from, and does it reach non-rural debts?

It comes from three places that must be read together. The proviso to s.36(1)(vii) says that where clause (viia) applies to the assessee, the deduction for a bad debt written off is limited to the amount by which the debt exceeds the credit balance in the provision for bad and doubtful debts account made under clause (viia). Section 36(2)(v) adds a condition precedent: where the debt relates to advances made by an assessee to whom clause (viia) applies, no deduction is allowed at all unless the assessee has debited that debt, in that previous year, to the clause (viia) provision account. Explanation 2 to clause (vii), inserted by section 7 of the Finance Act, 2013 with effect from 1 April 2014, then declares that for the purposes of that proviso and of s.36(2)(v) the account referred to is "only one account" and that it "shall relate to all types of advances, including advances made by rural branches". Whether Explanation 2 displaces the Supreme Court's construction in Catholic Syrian Bank for a sub-clause (a) bank is contested and is dealt with separately in this library.

Decided by the CBDT Circulars & Instructions (Not applicable — statutory text), reported as Income-tax Act, 1961, s.36(1)(vii) with its provisos and Explanations and s.36(2)(v), as printed on the departmental Year 2025 edition (incometaxindia.gov.in/w/section-36-64) and the Year 2024 (No. 1) edition (/w/section-36-62); Explanation 2 as inserted by section 7 of the Finance Act, 2013 with effect from 1 April 2014. It bears on section 36(1)(vii), section 36(1)(viia), section 36(2), section 36(2)(v), section 145(2) of the Income Tax Act 1961, in Deductions & Disallowances, How Tax Law Is Read and Assessment & Scrutiny matters.

Still good law. The proviso, Explanation 1, Explanation 2 and s.36(2)(v) were transcribed from two departmental editions, Year 2025 and Year 2024 (No. 1), which agree word for word, and Explanation 2 additionally matches the text enacted by section 7 of the Finance Act, 2013. What the words MEAN for a bank taxed under sub-clause (a) of clause (viia) is a live dispute and is not settled by this entry: see the separate entry on Karnataka Bank Ltd v. DCIT. I did not carry out any survey of judicial treatment of the proviso beyond the four judgments read for this batch, and I did not read any Finance Act later than 2017 for this clause.

Why it matters

This is the single most litigated interaction in bank taxation, and the money is large. Three practical points. First, s.36(2)(v) is a book-entry condition, not a computational one: a bank that never debited the written-off debt to the clause (viia) provision account in that previous year fails at the threshold, whatever the arithmetic. Second, the proviso does not deny the write-off; it reduces it by the credit balance already allowed as a provision, and it exists to stop the same rural advance being relieved twice. Third, Explanation 2 was Parliament's answer to Catholic Syrian Bank Ltd v. CIT, and it does its work most obviously on assessees under sub-clauses (b), (c) and (d) — a foreign bank, a public financial institution, a State financial corporation, a State industrial investment corporation or an NBFC — which have no rural branches at all and could otherwise have argued that the proviso was spent on them. Whether it also reaches the non-rural bad debts of a sub-clause (a) bank has divided the Revenue from the Tribunal, and a practitioner must know which side of that line his client's year and sub-clause fall on. Note also the second proviso to clause (vii), which deals with a debt taken into account under an income computation and disclosure standard notified under s.145(2) without being recorded in the accounts: that debt is allowed in the year it becomes irrecoverable and is deemed to have been written off in the accounts. Finally, keep the vocabulary straight: the "provision" in clause (viia) is a TAX allowance capped by percentages in the Income-tax Act; the provisioning a bank makes under the Reserve Bank of India's prudential norms is a regulatory obligation and is not what the proviso measures.

Binding on the department, not on the assessee or the courts. An assessee may rely on a circular that is beneficial to them.

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Related

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