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आयकर अपील य अ धकरण, 'डी' यायपीठ, चे नई IN THE INCOME TAX APPELLATE TRIBUNAL ' D' BENCH : CHENNAI ी जॉज माथन, या यक सद य के सम एवं एस जयरामन, लेखा सद य BEFORE SHRI GEORGE MATHAN, JUDICIAL MEMBER & SHRI S.JAYARAMAN, ACCOUNTANT MEMBER I.T.A.Nos.1912 & 1913/CHNY/2017 & C.O. Nos.12 & 13/CHNY/2018 Assessment years : 2009-09 & 2009-10 The Deputy Commissioner of Vs. M/s. Infrastructure Development Income Tax, Finance Company Limited, Room No.512, 5th floor, KRM Towers, 8th floor, Wanaparthy Block, No.1,Harrington Road, Chetpet, Chennai-34. Chennai 600 031.

31. If each of the clauses under sub-section (1) of Section 36 is independent in its operation and if each one of them does not depend upon the other clause for the extension of the benefit, :- 8 -: ITA Nos.1912 & 1913/CHNY/17 C.O. Nos.12 & 13/CHNY/2018 then the interpretation given by the respondent cannot be accepted.

32. Yet another distinction brought forth by the learned counsel for the appellant, also deserves consideration. While the benefit of deduction under clause (viia)(c) is available to any public financial institution or State financial corporation or State industrial investment corporation, in respect of a provision for bad and doubtful debts, the benefit of the deduction under clause (viii) is available only for the financial corporations engaged in providing long-term finance for industrial or agricultural development or development of infrastructure facility in India. Therefore, if the interpretation as given by the authorities are accepted, the benefit that will accrue to a finance corporation incorporated in India and providing long-term finance for infrastructure development would be lesser than what is received by the foreign banks and foreign financial institutions. This could not have been the purport of the amendment brought forth under the Finance Bill, 1995.