UNISON HOTELS PVT LTD.,DELHI vs. ACIT, RANGE-27, NEW DELHI

ITA 4129/DEL/2024Status: DisposedITAT Delhi20 April 2026AY 2014-1523 pages
AI SummaryPartly Allowed

What were the facts?

The assessee company debited Rs. 4,90,65,185/- as advances written off in its Profit & Loss account, comprising inter-corporate deposits and transaction advances. The Assessing Officer disallowed this amount, holding that it did not meet the criteria for bad debt deduction under Section 36(1)(vii) and 36(2)(i) of the Income Tax Act.

What did the Tribunal hold?

The Tribunal allowed the deduction for Rs. 11,06,860/- relating to earnest money deposit for a joint bid to procure natural gas, considering it a revenue loss incurred for the purpose of business. However, the judgment does not explicitly detail the decision on the remaining amount of written-off advances.

What were the issues?

Whether advances written off, including inter-corporate deposits and earnest money for business purposes, qualify for deduction as bad debts or business losses.

Which sections of the Income-tax Act were involved?

Section 36(1)(vii),Section 36(2)(i),Section 37(1)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, DELHI BENCH, C: NEW DELHI

Before: SHRI CHALLA NAGENDRA PRASAD & SHRI BRAJESH KUMAR SINGH

For Appellant: Shri Kavita Jha, Sr. Adv, Shri Himanshu Aggarwal, Adv. &, Shri Akash Shukla, Adv
For Respondent: Shri Om Parkash, Sr. DR
Hearing: 19.01.2026Pronounced: 20.04.2026

PER BRAJESH KUMAR SINGH, AM,

This appeal by the Assessee is against the order of National Faceless Appeal Centre (NFAC) [hereinafter referred to as the ‘Ld. CIT(A)] order dated 12.08.2024 arising out of the assessment order dated 23.12.2016 passed under section 143(3) of the Income Tax Act, 1961 (hereinafter referred to as the ‘the Act’) passed by the ITA No.- 4129/Del/2024 M/s Unison Hotels Pvt. Ltd. Additional Commissioner of Income -tax, Range-27, New Delhi, (hereinafter referred to as the ‘AO’) pertaining to Assessment Year (AY) 2013-14. 2. Brief facts of the case: The assessee compan

The order continues below.

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