(i) DCIT v. Core Healthcare Ltd.

110 TTJ 170Income Tax Appellate Tribunal2007#6498 most cited

What is (i) DCIT v. Core Healthcare Ltd. authority for?

The principal amount written off is allowable as a deduction under Section 36(1)(vii) read with Section 36(2) of the Income Tax Act, even if the company is not engaged in the money lending business.

17

judgments rely on this decision, according to BharatTax’s citation analysis of 366,005 Indian tax judgments — from 2011 to 2024.

Also referred to as

DCIT v. Core Healthcare Ltd. · 110 TTJ 170 · Section 36(1)(vii) · Section 36(2) · deduction · principal amount written off · not in money lending business

Sections most often in play

Section 143(3)Section 14ASection 2(47)Section 28(iiid)Section 28(iiie)Section 35DSection 36(1)(vii)Section 36(2)

Issues it is cited on

section 35absection 35abbsection 80ia(1)bright line testamp expendituresection 35asection 92c(1)comparable uncontrolled price methodsection 80ia(4)far analysissection 194hdisallowance under section 40(a)(ia)

Judgments citing (i) DCIT v. Core Healthcare Ltd.

Bajaj Holdngs & Investment Ltd ( Erstwhile Bajaj Auto Ltd), Mumbai vs. Addl CIT RG 3(1), Mumbai

In the result, the appeal of the assessee is partly allowed and appeal of the revenue is dismissed

ITA 3043/MUM/2010[2002-013]Status: DisposedITAT Mumbai24 Jun 2024AY 2002-013

Bench: Shri Vikas Awasthy & Shri Amarjit Singhbajaj Holdings & Vs. Additional Commissioner Investment Ltd. Of Income-Tax, Range 3(1) Erstwile Bajaj Auto Ltd.) Aayakar Bhavan, Bajaj Bhavan, 226, M.K. Road, Nariman Point, Mumbai – 400 020 Mumbai – 400 021 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No:Aaacb3370K Appellant .. Respondent Dcit-3(4) Vs. M/S Bajaj Holding & Room No. 481-2, 4Th Floor, Investment Limited Aaykar Bhavan, (Erstwhile Bajaj Auto Ltd) Mumbai – 400020 226, Bajaj Bhavan, 2Nd Floor, Jamnalal Bajaj Marg, Nariman Point Mumbai – 400 021 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No:Aaacb3370K Appellant .. Respondent Appellant By : Percy Pardiwala & Vasanti Patel Respondent By : Ankush Kapoor

For Appellant: Percy Pardiwala &For Respondent: Ankush Kapoor
Section 143(3)Section 2(47)

…e amount written off was allowable as deduction u/s 36(1)(vii) r.w.s 36(2) of the Act. The ld. Counsel has also referred the following judicial pronouncements: (a) Poysha Oxygen (P) Ltd. Vs. ACIT in 19 SOT 711 (Delhi Tribunal) (b) ITW Signode India LTD [2007] 110 TTJ 170 (HYD.) (c) Shreyas S. Morakhia (2012) 342 ITR 0285 (Bombay High Court) (d) Pudumjee Pulp & Paper Mills Ltd ITA No. 1590 of 2013 dated 5 August 2015 (Bombay High Court) (e) Mahindra Engineering and Chemical Products Ltd. [2022] 136 taxmann.com 183 (Bombay) Allowability of deduction under section 36(1)(vii) read with section 36(2) of the Act even w…

Addl CIT RG 3(1), Mumbai vs. Bajaj Auto Ltd, Mumbai

In the result, the appeal of the assessee is partly allowed and appeal of the revenue is dismissed

ITA 2899/MUM/2010[2002-03]Status: DisposedITAT Mumbai24 Jun 2024AY 2002-03

Bench: Shri Vikas Awasthy & Shri Amarjit Singhbajaj Holdings & Vs. Additional Commissioner Investment Ltd. Of Income-Tax, Range 3(1) Erstwile Bajaj Auto Ltd.) Aayakar Bhavan, Bajaj Bhavan, 226, M.K. Road, Nariman Point, Mumbai – 400 020 Mumbai – 400 021 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No:Aaacb3370K Appellant .. Respondent Dcit-3(4) Vs. M/S Bajaj Holding & Room No. 481-2, 4Th Floor, Investment Limited Aaykar Bhavan, (Erstwhile Bajaj Auto Ltd) Mumbai – 400020 226, Bajaj Bhavan, 2Nd Floor, Jamnalal Bajaj Marg, Nariman Point Mumbai – 400 021 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No:Aaacb3370K Appellant .. Respondent Appellant By : Percy Pardiwala & Vasanti Patel Respondent By : Ankush Kapoor

For Appellant: Percy Pardiwala &For Respondent: Ankush Kapoor
Section 143(3)Section 2(47)

…e amount written off was allowable as deduction u/s 36(1)(vii) r.w.s 36(2) of the Act. The ld. Counsel has also referred the following judicial pronouncements: (a) Poysha Oxygen (P) Ltd. Vs. ACIT in 19 SOT 711 (Delhi Tribunal) (b) ITW Signode India LTD [2007] 110 TTJ 170 (HYD.) (c) Shreyas S. Morakhia (2012) 342 ITR 0285 (Bombay High Court) (d) Pudumjee Pulp & Paper Mills Ltd ITA No. 1590 of 2013 dated 5 August 2015 (Bombay High Court) (e) Mahindra Engineering and Chemical Products Ltd. [2022] 136 taxmann.com 183 (Bombay) Allowability of deduction under section 36(1)(vii) read with section 36(2) of the Act even w…

Vodafone India Limited, Mumbai vs. Assistant Commissioner of Income Tax-8(3)(2), Mumbai

ITA 2834/MUM/2017[2012-13]Status: DisposedITAT Mumbai17 May 2024AY 2012-13
For Appellant: Shri P.J. PardiwalaFor Respondent: Shri T. Sankar
Section 115JSection 143(3)Section 144C(13)Section 144C(5)Section 14ASection 234DSection 271(1)(c)Section 36(1)(iii)Section 37Section 40

…IN THE INCOME TAX APPELLATE TRIBUNAL "I" BENCH, MUMBAI SHRI S RIFAUR RAHMAN, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY, JUDICIAL MEMBER ITA No. 884/MUM/2016 (Assessment Year: 2011-12) & ITA No. 2834/MUM/2017 (Assessment Year: 2012-13) Vodafone India Ltd., Peninsula Corporate Park, Ganpatrao Kadam Marg, Lower Parel, Mumbai - 400013 [PAN: AAACH5332B] Assistant Commissioner of Income Tax- 8(3)(2), Mumbai, Vs .............Appellant .....Respondent ITA No. 1916/MUM/2016 (Assessment Year: 2011-12) Deputy Commissioner of Income Tax 5(2)(1), Mumbai, 5th Floor, Room No. 525, Aayakar Bhavan, M.K. Road, Mumbai - 400020 Appella…

Vodafone India Ltd, Mumbai vs. Asst CIT 8(3)(2), Mumbai

ITA 884/MUM/2016[2011-12]Status: DisposedITAT Mumbai17 May 2024AY 2011-12
Section 115JSection 143(3)Section 144C(13)Section 144C(5)Section 14ASection 234DSection 271(1)(c)Section 36(1)(iii)Section 37Section 40

…l area of operation remain confined to Mumbai Telecom Circle. The Id. Counsel for the assessee in support of his submissions placed reliance on the following decisions: (i) DCIT vs. Core Healthcare Ltd., 252 ITR 61 (Guj). (ii) ITW Signode India Ltd. vs. DCIT, 110 TTJ 170 (Hyd-Trb) XX XX 21. Per contra, the Id. Departmental Representative vehemently defending the assessment order submitted that the assessee had acquired loans and raised ECBs for expansion of business. With the acquisition of new assets, the subscriber base of the assessee has increased, the increase in subscriber base is also an extension of busin…

DCIT 8(3)(2), Mumbai vs. M/S Vodafone Idea Limited (Earlier Known As Vodafone India Limited Which Now Stands Merged With Idea Cellular Limited (Icl) and Consequently Known As Vodafone Idea Limited), Mumbai

ITA 1919/MUM/2016[2011-12]Status: DisposedITAT Mumbai17 May 2024AY 2011-12
For Appellant: Shri P.J. PardiwalaFor Respondent: Shri T. Sankar
Section 115JSection 143(3)Section 144C(13)Section 144C(5)Section 14ASection 234DSection 271(1)(c)Section 36(1)(iii)Section 37Section 40

…IN THE INCOME TAX APPELLATE TRIBUNAL "I" BENCH, MUMBAI SHRI S RIFAUR RAHMAN, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY, JUDICIAL MEMBER ITA No. 884/MUM/2016 (Assessment Year: 2011-12) & ITA No. 2834/MUM/2017 (Assessment Year: 2012-13) Vodafone India Ltd., Peninsula Corporate Park, Ganpatrao Kadam Marg, Lower Parel, Mumbai - 400013 [PAN: AAACH5332B] Assistant Commissioner of Income Tax- 8(3)(2), Mumbai, Vs ............. Appellant .... Respondent ITA No. 1916/MUM/2016 (Assessment Year: 2011-12) Deputy Commissioner of Income Tax 5(2)(1), Mumbai, 5th Floor, Room No. 525, Aayakar Bhavan, M.K. Road, Mumbai - 400020 Appell…

Vodafone India Ltd, Mumbai vs. DCIT 7(3), Mumbai

In the result, the appeal of the assessee is treated as allowed and the appeal of the revenue is dismissed

ITA 1121/MUM/2014[2009-10]Status: DisposedITAT Mumbai08 Nov 2023AY 2009-10

Bench: Shri B.R. Baskaran (Am) & Shri Pavan Kumar Gadale (Jm)

Section 143(3)Section 3Section 80Section 80I

…area of operation remain confined to Mumbai Telecom Circle. The ld. Counsel for the assessee in support of his submissions placed reliance on the following decisions: (i) DCIT vs. Core Healthcare Ltd., 252 ITR 61 (Guj). (ii) ITW Signode India Ltd. vs. DCIT, 110 TTJ 170 (Hyd-Trb) In respect of ECBs the ld. Counsel for the assessee submits that ECB was raised by the assessee for the purpose of acquiring fixed assets for supporting and smooth running of existing business. The ECB loan was received on 10/03/2006 and the same was not utilized up to end of the Financial Year 2006 i.e. 31/03/2006. The interest cost o…

Vodafone Essar Ltd., Mumbai vs. Addl. CIT, Chandigarh

ITA 216/CHANDI/2011[2006-07]Status: DisposedITAT Mumbai16 Mar 2023AY 2006-07

Bench: Shri Vikas Awasthy & Shri M. Balaganeshआअसं. 216/ चंडी/2011 (िन.व. 2006-07) आअसं. 1173/चांडी /2011 (िन.व. 2007-08) Vodafone India Ltd. (Formerly Known As ‘ Vodafone Essar Limited’) Peninsula Corporate Park, Ganpatrao Kadam Marg, Lower Parel, Mumbai – 400 013. ...... अपीलाथ"/Appellant Pan:Aaach-5332-B बनाम Vs. Additional Commissioner Of Income Tax, Range -1, ..... ""तवाद"/Respondent Chandigarh. अपीलाथ" "वारा/ Appellant By : Shri Salil Kapoor With S/Shri Vibhu Jain & Ninad Patade ""तवाद" "वारा/Respondent By : Shri Anand Mohan

For Appellant: Shri Salil Kapoor with S/Shri Vibhu Jain and Ninad PatadeFor Respondent: Shri Anand Mohan
Section 115JSection 144C(13)Section 14ASection 234BSection 271(1)(c)Section 40Section 80I

…area of operation remain confined to Mumbai Telecom Circle. The ld. Counsel for the assessee in support of his submissions placed reliance on the following decisions: (i) DCIT vs. Core Healthcare Ltd., 252 ITR 61 (Guj). (ii) ITW Signode India Ltd. vs. DCIT, 110 TTJ 170 (Hyd-Trb) In respect of ECBs the ld. Counsel for the assessee submits that ECB was raised by the assessee for the purpose of acquiring fixed assets for supporting and smooth running of existing business. The ECB loan was received on 10/03/2006 and the same was not utilized up to end of the Financial Year 2006 i.e. 31/03/2006. The interest cost on…

M/S Vodafone Essar Ltd., Mumbai vs. Addl. CIT, Chandigarh

ITA 1173/CHANDI/2011[2007-08]Status: DisposedITAT Mumbai16 Mar 2023AY 2007-08

Bench: Shri Vikas Awasthy & Shri M. Balaganeshआअसं. 216/ चंडी/2011 (िन.व. 2006-07) आअसं. 1173/चांडी /2011 (िन.व. 2007-08) Vodafone India Ltd. (Formerly Known As ‘ Vodafone Essar Limited’) Peninsula Corporate Park, Ganpatrao Kadam Marg, Lower Parel, Mumbai – 400 013. ...... अपीलाथ"/Appellant Pan:Aaach-5332-B बनाम Vs. Additional Commissioner Of Income Tax, Range -1, ..... ""तवाद"/Respondent Chandigarh. अपीलाथ" "वारा/ Appellant By : Shri Salil Kapoor With S/Shri Vibhu Jain & Ninad Patade ""तवाद" "वारा/Respondent By : Shri Anand Mohan

For Appellant: Shri Salil Kapoor with S/Shri Vibhu Jain and Ninad PatadeFor Respondent: Shri Anand Mohan
Section 115JSection 144C(13)Section 14ASection 234BSection 271(1)(c)Section 40Section 80I

…area of operation remain confined to Mumbai Telecom Circle. The ld. Counsel for the assessee in support of his submissions placed reliance on the following decisions: (i) DCIT vs. Core Healthcare Ltd., 252 ITR 61 (Guj). (ii) ITW Signode India Ltd. vs. DCIT, 110 TTJ 170 (Hyd-Trb) In respect of ECBs the ld. Counsel for the assessee submits that ECB was raised by the assessee for the purpose of acquiring fixed assets for supporting and smooth running of existing business. The ECB loan was received on 10/03/2006 and the same was not utilized up to end of the Financial Year 2006 i.e. 31/03/2006. The interest cost on…

M/S. Rmz Hotels Private Limited, Bangalore vs. National E-Assessment Centre, Delhi

In the result, the appeal of the assessee is allowed

ITA 954/BANG/2022[2018-19]Status: DisposedITAT Bangalore22 Feb 2023AY 2018-19

Bench: Shri Chandra Poojariassessment Year: 2018-19

For Appellant: Shri V. Srinivasan, A.RFor Respondent: Shri Ganesh R. Ghale, Standing Counsel for Department
Section 234Section 255Section 255(3)Section 36

…lowing the above said decision of the co-ordinate bench rendered in assessee's own case on an identical issue, we direct the AO to delete this disallowance.” (iii) Decision of Hyderabad Bench of Tribunal in the case of M/s. ITW Signode India Ltd. reported in 110 TTJ 170, wherein held as under: “12. We have duly considered the rival contentions and the material on record. The facts are not in dispute. Recently, Supreme Court had the occasion to explain the meaning of the expression 'commercial expediency". It was explained that it is a term of wide import and includes such expenditure for which there may not be a…

Maxim India Integrated Circuit Design Pvt. Ltd., Bangalore vs. DCIT, Bangalore

In the result, the appeal of the assessee is treated as partly allowed for statistical purposes

ITA 411/BANG/2016[2011-12]Status: DisposedITAT Bangalore05 Jan 2021AY 2011-12

Bench: Shri George George K. & Shri B.R. Baskaranit(Tp)A No.411/Bang/2016 Assessment Year: 2011-12

For Appellant: Shri Padam Chand Khincha, A.RFor Respondent: Shri Rajesh Kumar Jha, D.R
Section 10ASection 143(3)

…16 Maxim India Integrated Circuit Design Pvt. Ltd., Bangalore Page 16 of 20 therefore, this proviso is not applicable in the present case. He placed reliance on the Tribunal order rendered in the case of ITVV Signode India Ltd. Vs. DCIT as reported in [2007] 110 TTJ 170 (Hyd.), copy available on pages 662 to 669 of paper book. He also placed reliance on the Tribunal order rendered in the case of AT & T Global Network Services (India) Pvt. Ltd. Vs.DCIT as reported in (2017) Tax Corp (A.T.) 57930 (ITAT-Delhi), copy available on pages 673 to 743 of paper book. He submitted that para no. 18 of this Tribunal order av…

M/S the Himalaya Drug Company, Bangalore vs. DCIT, Bangalore

In the result, the assessee’s appeal for Assessment Year 2011-12 is partly allowed

ITA 187/BANG/2015[2010-11]Status: DisposedITAT Bangalore30 Apr 2019AY 2010-11

Bench: Shri Jason P Boaz & Shri Laliet Kumarit(Tp)A No.187/Bang/2015 Assessment Year : 2010-11

For Appellant: Shri. Padam Chand Khincha, CAFor Respondent: Smt. Susan D. George, CIT-DR
Section 143(1)Section 143(3)Section 144C(5)Section 36(1)(iii)Section 92CSection 92C(2)

…proviso to section 36(1)(iii) of the Act would not be applicable or attracted in the case on hand. In this regard, inter alia, the learned AR placed reliance on the decisions of the ITAT – Hyderabad Bench in the case of ITW Signode India Ltd., Vs. DCIT (2007) 110 TTJ 170 and of the ITAT – Delhi Bench in the case of AT & T Global Network Services (India) (P) Ltd., Vs. DCIT (2017) 86 taxmann.com 158. 9.3 Per contra, the learned DR for Revenue relied on the findings in the order of assessment and contended that the AO was justified in making the impugned disallowance. 9.4.1 We have considered the rival contentions…

M/S. Delhi Gujarat Fleet Carrier, Gurgaon vs. DCIT, Gurgaon

The appeal is dismissed

ITA 1680/DEL/2015[2011-12]Status: DisposedITAT Delhi23 Apr 2018AY 2011-12

Bench: Shri H.S. Sidhu & Shri Prashant Maharishia Y 2011-12 M/S. Delhi Gujarat Fleet Carrier Vs Dcit 1/43, Shivaji Nagar, Circle I(1) Gurgaon Gurgaon (Pan Aaccd6847K) (Appellant) (Respondent)

For Appellant: Sh. Rohit Jain, AdvocateFor Respondent: Ms. Ashima Neb, Sr. DR
Section 143Section 31Section 36Section 36(1)(iii)

…INCOME TAX APPELLATE TRIBUNAL DELHI BENCH “B”: NEW DELHI BEFORE SHRI H.S. SIDHU, JUDICIAL MEMBER AND SHRI PRASHANT MAHARISHI, ACCOUNTANT MEMBER A Y 2011-12 M/s. Delhi Gujarat Fleet Carrier Vs DCIT 1/43, Shivaji Nagar, Circle I(1) Gurgaon Gurgaon (PAN AACCD6847K) (Appellant) (Respondent) Appellant by : Sh. Rohit Jain, Advocate Respondent by: Ms. Ashima Neb, Sr. DR Date of Hearing 30/01/2018 Date of pronouncement 23/04/2018 O R D E R Per Prashant Maharishi, Accountant Member 1. This appeal is filed by assessee against order of Ld. CIT (A), Gurgaon dated 01.01.2015 for A. Y. 2011-12 raising following grounds o…

M/S. at & T Global Network Services (India) Pvt. Ltd., Gurgaon vs. DCIT, New Delhi

In the result, appeal of the assessee is partly allowed and appeal of the revenue is dismissed

ITA 2538/DEL/2014[2009-10]Status: DisposedITAT Delhi18 Sept 2017AY 2009-10

Bench: Shri I.C.Sudhir & Shri Prashant Maharishiat & T Global Network Services Dcit, (India) Pvt Ltd., Circle-2(1), Vs. Vatika Lok-1, Block-A, Gurgaon New Delhi Pan:Aafca8810L (Appellant) (Respondent) Dcit, At & T Global Network Services Circle-2(1), (India) Pvt Ltd., Vs. New Delhi Vatika Lok-1, Block-A, Gurgaon Pan:Aafca8810L (Appellant) (Respondent)

For Appellant: Shri Kanchan Kaushal, CAFor Respondent: Shri N C Swain CIT DR
Section 143(3)Section 144CSection 144C(5)Section 32Section 36

…ot hit by the proviso to section 36(1) (iii) of the Act. Reliance was placed on the decision of ITAT in 15 | P a g e AT & T Global Network Services (India) Pvt Ltd V DCIT ITA No 2538/Del/2014 (A) & ITA NO 2518/Del/2014 (D) A Y 2009-10 the case of ITW Signode 110 TTJ 170 wherein it has been held that the term 'extension' connotes that the taxpayer has extended its operations from present activity to another activity. 7.4 The issue has been considered by the Panel. In the proviso to section 36(1)(iii), the word ―extension‖ has been used which is to be taken as synonymous to the word ―expansion‖ held in case of Na…

DCIT, Circle-1, Kolkata vs. M/S Mcnally Bharati Engineering Co.Ltd., Kolkata

In the result the appeal by the assessee is partly allowed

ITA 532/KOL/2012[2007-2008]Status: DisposedITAT Kolkata01 Mar 2017AY 2007-2008

Bench: Hon’Ble Sri N.V.Vasudevan, Jm & Shri Waseem Ahmed, Am] I.T.A No.100/Kol/2011 Assessment Year : 2006-07

For Appellant: Shri Soumen Adak, FCAFor Respondent: Shri Vijayendra Kumar, JCIT
Section 115JSection 43B

…ifiable details were produced to show immediate nexus with business. 66. On appeal by the Assessee, the CIT(A) relying on decision Hon’ble ITAT in assessee's own case in A.Y. 2003-04 and decision of Hon’ble Hyderabad ITAT in ITW Signode Ltd -vs.- DCIT (2007) 110 TTJ 170 (Hyd) held that advances written off in the course of business needs to be allowed u/s 28 read with section 37(1) of the Act. 67. Aggrieved by the order of CIT(A) the revenue has raised ground no.6 before the Tribunal. 68. We have heard the submissions of the ld. DR and the ld. Counsel for the assessee. The ld. DR relied on the order of AO. The…

ITO, New Delhi vs. M/S. Mahajan Industries P. Ltd., New Delhi

In the result, the appeal of the Revenue stands dismissed

ITA 6295/DEL/2013[2009-10]Status: DisposedITAT Delhi18 Mar 2016AY 2009-10

Bench: Shri Chandra Mohan Garg & Shri L.P. Sahu

For Appellant: Shri Rajesh Kumar Bhoot, CIT- DRFor Respondent: Shri C.S. Aggarwal, Sr. Adv
Section 143(1)Section 143(2)Section 143(3)Section 14A

…way of assessee in view of the finding that the money was lent in the ordinary course of business of the assessee. 13.12 Lastly, the ld. AR placed reliance on the decision of the ITAT, Hyderabad ‘Á’ Bench in the case of ITW Signod I Ltd Vs. DCIT reported as 110 TTJ 170 [Hyd. Trib] wherein it has been held as under: “It is also not uncommon that at certain points of time, companies may have surplus funds awaiting fruitful deployment. Pending such deployment, they park their funds to earn interest. Earning of interest on surplus funds is also on grounds of commercial expediency as such income would ultimately au…

Dy Commissioner of Income Tax vs. Insilco Ltd

The appeal is dismissed

ITA/311/2011HC Delhi29 Apr 2011

Bench: HON'BLE MR. JUSTICE A.K.SIKRI,HON'BLE MR. JUSTICE M.L. MEHTA

Section 260ASection 263Section 36(1)(vii)Section 36(2)Section 37

…ing the powers under Section 263 of the Act. ITAs No.311/2011 Page 7 of 9 9. The Tribunal further observed that the decision of the AO was based on the decision of Coordinate Bench in the case of Singnode India Limited reported in 110 TTJ 170, which is to the effect that in respect of inter-corporate deposits, the amount is capable of being treated as a bad debt and allowable as such. Thus, the view of the AO is also supported by the decision of their Coordinate Bench. The Tribunal also observed that it cannot be said that there is an error, much less an error prejudicial to…

Dy. Commissioner of Income Tax vs. M/s.Insilco Ltd

The appeal is dismissed

ITA-311/2011HC Delhi29 Apr 2011
Section 260ASection 263Section 36(1)(vii)Section 36(2)Section 37

…der Section 263 of the Act. 2011:DHC:2435-DB ITAs No.311/2011 Page 7 of 9 9. The Tribunal further observed that the decision of the AO was based on the decision of Coordinate Bench in the case of Singnode India Limited reported in 110 TTJ 170, which is to the effect that in respect of inter-corporate deposits, the amount is capable of being treated as a bad debt and allowable as such. Thus, the view of the AO is also supported by the decision of their Coordinate Bench. The Tribunal also observed that it cannot be said that there is an error, much less an error prejudicial to…

(i) DCIT v. Core Healthcare Ltd. (110 TTJ 170) — Cited in 17 Judgments | BharatTax