` I N THE I NCOME TAX APPELLATE TRI BUNAL “DB” BENCH, COCHI N SHRI I NTURI RAMA RAO, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY, JUDI CI AL MEMBER I TA No.542/ COCH/ 2025 (Assessment Year:2014-2015)

Dy. Commissioner of I ncome Tax Ayakar Bhavan, Shakthan, Thampuran Nagar, Thrissur, Thrissur Kerala- 680006 …………. Appellant Vs The CSB Bank Ltd ST. Thomas College Road, Thrissur, Thrissur, Kerala- 680020 [PAN: AABCT0024D] …………. Respondent Appearance For the Appellant/Assessee : Shri Satish Modi, CA For the Respondent/Department : Shri. Sanjit Kumar Das, CIT DR Date Conclusion of hearing : 20.08.2025 Pronouncement of order : 30.10.2025

O R D E R

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Per Rahul Chaudhary, Judicial Member:

1. The present appeal preferred by the Revenue is directed against the order, dated 25/03/2025, passed by National Faceless Appeal Centre (NFAC), Delhi [hereinafter referred to as ‘the NFAC’] under Section 250 of the Income Tax Act, 1961 [hereinafter referred to as ‘the Act’] whereby the Ld. CIT(A) had partly allowed the appeal against the Assessment Order, dated 16/03/2022, passed under Section 147 read with Section 144B of the Act for the Assessment Year 2014-

2015.

1.1. The appeal preferred by the Revenue was delayed by 60 days. We have head both the sides on application for condonation of delay. The Hon’ble Supreme Court had, in the case of Collector of Land Acquisition Vs. Mst. Katiji & others AI R 1987 1353 (SC), held that the substantial justice should prevail over technical considerations. Refusing to condone delay can result in a meritorious matter being thrown out at the very threshold. As against this, when delay is condoned, the highest that can happen is that a cause would be decided on merits after hearing the parties. As per the affidavit filed by the Revenue in support of the application seeking condonation of delay, the delay was neither intentional nor due to negligence but was occasion on account multiple charges with heavy work load being handled by the assessing officer concerned at the relevant time. Therefore, we are of the view that the Revenue was prevented by reasonable cause from filing appeal within the prescribed time and that no benefit would have accrued to the Revenue by delaying filing of the present appeal. Therefore, in view of the judgment of the Hon’ble Supreme Court in the case of Collector of Land Acquisition Vs. Mst. Katiji & others (supra), we condone the delay of 60 days in filing the present appeal and proceed to examine the grounds raised in the present appeal.

2. The Revenue has raised following grounds of appeal :

“1. The order of the Commissioner of Income Tax (Appeals), National Faceless Appeal Centre [NFAC], New Delhi in DIN and Order No. DIN ITBA/APLS/S/250/2024-25/1074993866(1) dated 25.03.2025 against assessment Order u/s.147 r.w.s 260 of the Income tax Act, 1961 for the Assessment. Year 2013-14 is erroneous in law, facts and circumstances of the case.

2 The assessment was completed by an addition on the Book Profit.

That the amount set aside to provisions made for meeting liabilities, other than ascertained liabilities are to be added to the profit shown in the profit and loss account. Therefore, there is a shortfall in computation of book profit to the tune of Rs: 57.57 crore.

The learned CIT(A) NFAC, New Delhi held that appellant has rightly debited the provisions of bad and doubtful debts in profit and loss account, simultaneously also reduce loans and advances or the debtors from the asset side of the balance sheet to the extent of the corresponding amount. Consequently, at the end of the year, the amount of loans and advances/debtors is shown as net of provisions for bad debt. Therefore, question of disallowance u/s. 115JB of the Income tax Act does not arise. Therefore, disallowance of provisions of bad and doubtful debts to the extent of Rs. 57.57 crores is deleted.

3. The CIT(A) has erred on the following points while deleting the Book profit enhancement consequent to bad and doubtful debt the extent of Rs.