Minda HUF v. JCT

101 ITD 191Income Tax Appellate Tribunal2006#6939 most cited
16

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2017 to 2023.

Judgments citing Minda HUF v. JCT

ECI ENGINEERING & CONSTRUCTION COMPANY LTD., HYD,HYDERABAD vs. ACIT, CIRCLE-2(2), HYD, HYDERABAD

In the result, the appeal of the assessee is allowed

ITA 968/HYD/2016[2006-07]Status: DisposedITAT Hyderabad15 May 2023AY 2006-07

Bench: Shri R.K. Panda & Shri Laliet Kumarassessment Year: 2006-07 The Asst. Commissioner Of Vs. M/S. Eci Engineering & Income Tax, Construction Co., Ltd., Circle 17(1), Hyderabad. Hyderabad. Pan : Aaace74411G (Appellant) (Respondent) Ita 968/Hyd/2016 Assessment Year 2006-07 M/S. Eci Engineering & Vs. The Asst. Commissioner Of Construction Co., Ltd., Income Tax, Hyderabad. Circle 2(2), Hyderabad. Pan : Aaace74411G (Appellant) (Respondent) Assessee By: Shri K.C. Devdas Revenue By: Shri K.P.R.R. Murthy. Date Of Hearing: 27.03.2023 Date Of Pronouncement: 15.05.2023 O R D E R Per Laliet Kumar, J.M. These Two Appeals Filed By The Assessee & The Revenue, Respectively, Are Directed Against The Order Of Commissioner Of Income Tax (Appeals) – 5, Hyderabad Dated 30.03.2016 For The Assessment Year 2006-07. 2. The Abridged Grounds Raised By The Assessee In Ita No.968/Hyd/2016 Read As Under : “1. The Order Of Ld.Cit(A) - 5 Is Erroneous In Law In Facts & In Law. 2. The Ld.Cit(A) Erred In Upholding The Decision Of The Ld.Ao In Treating Sale Of Partly Paid Up Shares As Fully Paid & Confirming The Addition Of Rs.50,14,625/- As Long Term Capital Gain. 3. The Ld.Cit(A) Erred In Confirming The Addition Of Rs.27,69,422/- Towards Difference In Interest. 4. Further, The Ld.Cit(A) Failed To Observe That The Notes To Financial Statements Clearly Mentioned The Interest Income Which Pertained To The Previous Year & Accordingly Erred In Upholding The Action Of The Ld.Ao In Assessing The Difference In Interest Of Rs.27,69,422/-. 5. The Ld.Cit(A) Erred In Confirming The Addition Of Difference Of Prior Period Income Of Rs.1,26,71,371/-.”

For Appellant: Shri K.C. DevdasFor Respondent: Shri K.P.R.R. Murthy
Section 143(1)Section 143(3)Section 148Section 40

…e following decisions: i. CIT v. Omer Khayyam Wineries (P.) Ltd. [1979] 120 ITR 859 (AP.HC) ii.Eimco K.C.P.Ltd. vs CIT [2000] 109 taxman 151(SC) (SC) iii. CIT vs. Mohan Steel Ltd. [2005] 273 ITR 479 (Alahabad HC) iv.MAC Industrial Products Ltd. ACIT,CC [2006] 101 ITD 191 (ITAT, Chennai) v.CIT vs. Reinz Talbros (P.) Ltd. [2001] 119 taxman 739 (Del.HC) 19. He accordingly submitted that the order of the ld.CIT(A) being in accordance with law has to be upheld and the grounds raised by the assessee should be dismissed. 20. We have considered the rival arguments made by both the sides, perused the orders of the AO and…

DCIT, CIRCLE-17(1), HYD, HYDERABAD vs. ECI ENGINEERING & CONSTRUCTION CO. LTD., HYD, HYDERABAD

In the result, the appeal of the assessee is allowed

ITA 930/HYD/2016[2006-07]Status: DisposedITAT Hyderabad15 May 2023AY 2006-07

Bench: Shri R.K. Panda & Shri Laliet Kumarassessment Year: 2006-07 The Asst. Commissioner Of Vs. M/S. Eci Engineering & Income Tax, Construction Co., Ltd., Circle 17(1), Hyderabad. Hyderabad. Pan : Aaace74411G (Appellant) (Respondent) Ita 968/Hyd/2016 Assessment Year 2006-07 M/S. Eci Engineering & Vs. The Asst. Commissioner Of Construction Co., Ltd., Income Tax, Hyderabad. Circle 2(2), Hyderabad. Pan : Aaace74411G (Appellant) (Respondent) Assessee By: Shri K.C. Devdas Revenue By: Shri K.P.R.R. Murthy. Date Of Hearing: 27.03.2023 Date Of Pronouncement: 15.05.2023 O R D E R Per Laliet Kumar, J.M. These Two Appeals Filed By The Assessee & The Revenue, Respectively, Are Directed Against The Order Of Commissioner Of Income Tax (Appeals) – 5, Hyderabad Dated 30.03.2016 For The Assessment Year 2006-07. 2. The Abridged Grounds Raised By The Assessee In Ita No.968/Hyd/2016 Read As Under : “1. The Order Of Ld.Cit(A) - 5 Is Erroneous In Law In Facts & In Law. 2. The Ld.Cit(A) Erred In Upholding The Decision Of The Ld.Ao In Treating Sale Of Partly Paid Up Shares As Fully Paid & Confirming The Addition Of Rs.50,14,625/- As Long Term Capital Gain. 3. The Ld.Cit(A) Erred In Confirming The Addition Of Rs.27,69,422/- Towards Difference In Interest. 4. Further, The Ld.Cit(A) Failed To Observe That The Notes To Financial Statements Clearly Mentioned The Interest Income Which Pertained To The Previous Year & Accordingly Erred In Upholding The Action Of The Ld.Ao In Assessing The Difference In Interest Of Rs.27,69,422/-. 5. The Ld.Cit(A) Erred In Confirming The Addition Of Difference Of Prior Period Income Of Rs.1,26,71,371/-.”

For Appellant: Shri K.C. DevdasFor Respondent: Shri K.P.R.R. Murthy
Section 143(1)Section 143(3)Section 148Section 40

…e following decisions: i. CIT v. Omer Khayyam Wineries (P.) Ltd. [1979] 120 ITR 859 (AP.HC) ii.Eimco K.C.P.Ltd. vs CIT [2000] 109 taxman 151(SC) (SC) iii. CIT vs. Mohan Steel Ltd. [2005] 273 ITR 479 (Alahabad HC) iv.MAC Industrial Products Ltd. ACIT,CC [2006] 101 ITD 191 (ITAT, Chennai) v.CIT vs. Reinz Talbros (P.) Ltd. [2001] 119 taxman 739 (Del.HC) 19. He accordingly submitted that the order of the ld.CIT(A) being in accordance with law has to be upheld and the grounds raised by the assessee should be dismissed. 20. We have considered the rival arguments made by both the sides, perused the orders of the AO and…

JCIT, NEW DELHI vs. M/S. DAAWAT FOODS LTD., NEW DELHI

In the result, the appeal of the assessee is partly allowed as indicated above and the appeal of the Revenue is dismissed

ITA 2387/DEL/2017[2010-11]Status: DisposedITAT Delhi04 May 2023AY 2010-11

Bench: Shri G. S. Pannua N D Shri Challa Nagendra Prasad

For Appellant: Ms. Deepashree Rao, C.A
Section 10Section 14A

…s bad debt. Cross I.T.A. Nos. 1758 & 2387/Del/2017 Reliance was placed on the decision of the Hon’ble Delhi High Court in the case of Mohan Meakin Ltd. Vs. CIT [348 ITR 109]; DCIT Vs. M/s. Edelweiss Capital Ltd. [ITA. No. 3971/Mum/2009]; Minda HUF Vs. JCIT [101 ITD 191 (Del.)] and Salora International Ltd. Vs. JCIT [129 taxmann.com 68 (Del)]. 13. On the other hand, the ld. DR strongly placed reliance on the orders of the authorities below. 14. Heard rival submissions perused the orders of the authorities below and the decisions relied on. On perusal of the order of the Assessing Officer as well as the ld. CIT (…

DAWAT FOODS LTD.,GURGAON vs. ACIT, NEW DELHI

In the result, the appeal of the assessee is partly allowed as indicated above and the appeal of the Revenue is dismissed

ITA 1758/DEL/2017[2010-11]Status: DisposedITAT Delhi04 May 2023AY 2010-11

Bench: Shri G. S. Pannua N D Shri Challa Nagendra Prasad

For Appellant: Ms. Deepashree Rao, C.A
Section 10Section 14A

…s bad debt. Cross I.T.A. Nos. 1758 & 2387/Del/2017 Reliance was placed on the decision of the Hon’ble Delhi High Court in the case of Mohan Meakin Ltd. Vs. CIT [348 ITR 109]; DCIT Vs. M/s. Edelweiss Capital Ltd. [ITA. No. 3971/Mum/2009]; Minda HUF Vs. JCIT [101 ITD 191 (Del.)] and Salora International Ltd. Vs. JCIT [129 taxmann.com 68 (Del)]. 13. On the other hand, the ld. DR strongly placed reliance on the orders of the authorities below. 14. Heard rival submissions perused the orders of the authorities below and the decisions relied on. On perusal of the order of the Assessing Officer as well as the ld. CIT (…

GMR AIR CARGO & AEROSPACE ENGINEERING LTD(SUCCESSOR TO GMR HYDERABAD AIR CARGO & LOGISTICS PVT LTD),SHAMSHABAD vs. INCOME TAX OFFICER, WARD-2(3) , HYDERABAD

In the result, the appeal filed by the assessee is allowed

ITA 183/HYD/2020[2008-09]Status: DisposedITAT Hyderabad14 Sept 2022AY 2008-09

Bench: Shri Rama Kanta Panda & Shri Laliet Kumarassessment Year: 2008-09 Gmr Air Cargo & Vs. Ito,Ward-2(3) Aerospace Engineering Signature Towers Ltd.(Successor To Gmr Kondapur, Kothaguda Hyderabad Air Cargo & Opp. Botanical Gardens Logistics Pvt Ltd.) R.R.District Rajiv Gandhi International Hyderabad-500 084 Airport, Samshabad Hyderabad-500 409

For Appellant: Shri K.C.DevdasFor Respondent: Shri Kumar Aditya, Sr.AR
Section 143(1)Section 143(3)Section 147Section 148Section 37

…following decisions: i. CIT v. Omer Khayyam Wineries (P.) Ltd. [1979] 120 ITR 859 (AP.HC) ii.Eimco K.C.P.Ltd. vs CIT [2000] 109 taxman 151(SC) (SC) iii. CIT vs. Mohan Steel Ltd. [2005] 273 ITR 479 (Alahabad HC) iv.MAC Industrial Products Ltd. ACIT,CC [2006] 101 ITD 191 (ITAT, Chennai) v.CIT vs. Reinz Talbros (P.) Ltd. [2001] 119 taxman 739 (Del.HC) 19. He accordingly submitted that the order of the ld.CIT(A) being in accordance with law has to be upheld and the grounds raised by the assessee should be dismissed. 20. We have considered the rival arguments made by both the sides, perused the orders of the AO an…

HBA STUDIO PVT. LTD.,NEW DELHI vs. DCIT, CIRCLE- 11(1), NEW DELHI

Appeal is allowed

ITA 4015/DEL/2018[2014-15]Status: DisposedITAT Delhi15 Mar 2022AY 2014-15

Bench: Sh. Anil Chaturvedi & Sh. Anubhav Sharmam/S. Hba Studio Pvt. Ltd. Vs. Dcit, L-41, Connaught Circus, Circle-11(1), New Delhi-110001 New Delhi Pan – Aabch8171R (Appellant) (Respondent)

Section 143(3)Section 250(6)Section 28Section 37(1)

…e Act. He relied the judgment of Delhi High Court in (i) Mohan Meakin Ltd. vs. Commissioner of Income-tax, Delhi [2011] 11 taxmann.com 141 (Delhi HC), (ii) CIT vs. Samara India (P.) Ltd. [2013] 35 taxmann.com 79 (Delhi) , (iii) Minda (HUF) Ltd. v. JCIT [2006] 101 ITD 191 (Delhi Trib.), (iv) ACIT vs. Set India (P) Ltd. [2010] 3 ITR (Trib.) 454 (MUM), (v) Vijayashanthi Builders Ltd. vs. JCIT [2016] 69 taxmann.com 31 (Chennai-Trib.), (vi) Badridas Daga v. CIT[1058] 34 ITR 10 (SC) (vii) DCIT v. Friends Shoe Company [2016] 74 taxmann.com 100(Visakhapatnam- Trib.), (viii) Chenab Forest Co. vs. Commissioner of Income-ta…

M/S. LUCKY EXPORTS,NEW DELHI vs. DCIT, NEW DELHI

In the result, the appeal filed by the assessee is allowed

ITA 771/DEL/2014[2008-09]Status: DisposedITAT Delhi28 Sept 2020AY 2008-09

Bench: Shri R.K. Panda & Shri Kuldip Singhassessment Year: 2008-09 Lucky Exports, Vs Dcit, Ug-28, Som Dutt Chambers-Ii, Circle-24(1), 9, Bhikaji Cama Place, New Delhi. New Delhi. Pan: Aaafl1147P (Appellant) (Respondent) Assessee By : Shri Naveen N.D. Gupta, Ca Revenue By : Shri Saras Kumar, Sr. Dr Date Of Hearing : 20.08.2020 Date Of Pronouncement : 28.09.2020 Order Per R.K. Panda, Am: This Appeal Filed By The Assessee Is Directed Against The Order Dated 21.11.2013 Of The Cit(A)-28, New Delhi Relating To Assessment Year 2008-09. 2. Facts Of The Case, In Brief, Are That The Assessee Is A Partnership Firm & Is Engaged In The Business As Merchant Exporter. It Filed Its Return Of Income On 27Th September, 2008 Declaring The Total Income At Rs.2,96,21,168/-. During The Course Of Assessment Proceedings, The Ao Observed From The Profit & Loss Account That The Assessee Has Claimed A Sum Of Rs.1,61,35,879/- Under The Head ‘Write Off/Bad Debt.’ He, Therefore, Asked The Assessee To Explain & Justify The Advances /Bad Debt Written Off In Respect Of 22 Parties. He Asked The Assessee To File Partywise Explanation & Justification Of Bad Debt/Advances Written Off & To Produce The Copy Of Account & Names Of Such Parties For The Last Three Years. He Also Asked The Assessee To File: (A) Copy Of Bank Statement When Payment Of Advances Written Off Were Made; (B) Complete Name, Address, Pan & Contact Details Of The Parties Including Current Address, If Any; & (C) Copy Of Correspondence Made In Connection With Recovery Of Loan/Advances Written Off.

For Appellant: Shri Naveen N.D. Gupta, CAFor Respondent: Shri Saras Kumar, Sr. DR
Section 37Section 37(1)

…in the said decision has held that non-recovery of trade advances amounted to business loss and were to be allowed as deduction u/s 28(1) and 37(1). 10. Referring to the decision of the co-ordinate Bench of the Tribunal in the case of Minda (HUF) Ltd. (2006) 101 ITD 191, he submitted that in that case, the assessee, during the course of its business gave advances to vendors for supply of raw materials, etc., which became irrecoverable due to either material was not supplied or defective material was supplied. The assessee wrote off the said amount as advance irrecoverable and claimed deduction thereof. The Tribu…

SHRI PRAVEEN GUPTA,GURGAON vs. ACIT, MEERUT

In the result, the appeal of the assessee is dismissed

ITA 1434/DEL/2016[2011-12]Status: DisposedITAT Delhi03 Sept 2019AY 2011-12

Bench: Shri H.S.Sidhu & Shri Anadee Nath Misshra

Section 143(3)Section 36Section 36(1)(viii)Section 37Section 68

…bunal (in short “ITAT”), the following particulars were filed from the assessee’s side:- 1. Balance Sheet 31.03.2011 2. Copy of account Arshad Ahmad 3. Copy of Bad Debts account 4. Judgement 190 Taxmann 391 (SC) 5. Judgement 190 Taxmann 257 (SC) 6. Judgement 101 ITD 191 (Delhi) 7. Paper cutting dated 04.03.2015 8. Remand Report dated 05.10.2015 9. Purchase Deed 10. Sale Deed [C.1]. At the time of hearing before us, Ld.AR of the assessee relied on the aforesaid particulars filed from assessee’s side in ITAT. Ld.AR for the assessee drew our particular attention to paper cutting dated 04.03.2015 in support of…

LANDBASE INDIA LTD.,GURGAON vs. DCIT, NEW DELHI

In the result, appeal of the assessee for assessment year 2011-12 is allowed

ITA 4999/DEL/2015[2011-12]Status: DisposedITAT Delhi26 Aug 2019AY 2011-12

Bench: Smt Beena A Pillai & Shri Prashant Maharishi

For Appellant: Shri Rohit Jain, AdvFor Respondent: Shri J. K. Mishra, CIT DR
Section 143(3)Section 147Section 148Section 32(1)

…, thus, if any such amount become irrecoverable, the same would be, it is submitted, allowable as trading loss under section 28 of the Act. Attention in this regard is invited to the decision of the Delhi Bench of the Tribunal in the case of Minda HUF v. JCT: 101 ITD 191. In that case the Tribunal was pleased to hold that the CIT (A) erred in not allowing the claim of the assessee in respect of the advances written off which had become irrecoverable. The relevant observations of the Tribunal are reproduced herein-below for ready reference: “We have carefully considered the entire material on record and the rival…

LANDBASE INDIA LTD.,GURGAON vs. DCIT, NEW DELHI

In the result, appeal of the assessee for assessment year 2011-12 is allowed

ITA 4998/DEL/2015[2010-11]Status: DisposedITAT Delhi26 Aug 2019AY 2010-11

Bench: Smt Beena A Pillai & Shri Prashant Maharishi

For Appellant: Shri Rohit Jain, AdvFor Respondent: Shri J. K. Mishra, CIT DR
Section 143(3)Section 147Section 148Section 32(1)

…, thus, if any such amount become irrecoverable, the same would be, it is submitted, allowable as trading loss under section 28 of the Act. Attention in this regard is invited to the decision of the Delhi Bench of the Tribunal in the case of Minda HUF v. JCT: 101 ITD 191. In that case the Tribunal was pleased to hold that the CIT (A) erred in not allowing the claim of the assessee in respect of the advances written off which had become irrecoverable. The relevant observations of the Tribunal are reproduced herein-below for ready reference: “We have carefully considered the entire material on record and the rival…

LANDBASE INDIA LTD.,NEW DELHI vs. DCIT, NEW DELHI

In the result, appeal of the assessee for assessment year 2011-12 is allowed

ITA 4560/DEL/2011[2005-06]Status: DisposedITAT Delhi26 Aug 2019AY 2005-06

Bench: Smt Beena A Pillai & Shri Prashant Maharishi

For Appellant: Shri Rohit Jain, AdvFor Respondent: Shri J. K. Mishra, CIT DR
Section 143(3)Section 147Section 148Section 32(1)

…, thus, if any such amount become irrecoverable, the same would be, it is submitted, allowable as trading loss under section 28 of the Act. Attention in this regard is invited to the decision of the Delhi Bench of the Tribunal in the case of Minda HUF v. JCT: 101 ITD 191. In that case the Tribunal was pleased to hold that the CIT (A) erred in not allowing the claim of the assessee in respect of the advances written off which had become irrecoverable. The relevant observations of the Tribunal are reproduced herein-below for ready reference: “We have carefully considered the entire material on record and the rival…

M/S LANDBASE INDIA LTD.,,GURGAON vs. ACIT, NEW DELHI

In the result, appeal of the assessee for assessment year 2011-12 is allowed

ITA 138/DEL/2016[2012-13]Status: DisposedITAT Delhi26 Aug 2019AY 2012-13

Bench: Smt Beena A Pillai & Shri Prashant Maharishi

For Appellant: Shri Rohit Jain, AdvFor Respondent: Shri J. K. Mishra, CIT DR
Section 143(3)Section 147Section 148Section 32(1)

…, thus, if any such amount become irrecoverable, the same would be, it is submitted, allowable as trading loss under section 28 of the Act. Attention in this regard is invited to the decision of the Delhi Bench of the Tribunal in the case of Minda HUF v. JCT: 101 ITD 191. In that case the Tribunal was pleased to hold that the CIT (A) erred in not allowing the claim of the assessee in respect of the advances written off which had become irrecoverable. The relevant observations of the Tribunal are reproduced herein-below for ready reference: “We have carefully considered the entire material on record and the rival…

LANDBASE INDIA LTD.,NEW DELHI vs. DCIT, NEW DELHI

In the result, appeal of the assessee for assessment year 2011-12 is allowed

ITA 653/DEL/2011[2007-08]Status: DisposedITAT Delhi26 Aug 2019AY 2007-08

Bench: Smt Beena A Pillai & Shri Prashant Maharishi

For Appellant: Shri Rohit Jain, AdvFor Respondent: Shri J. K. Mishra, CIT DR
Section 143(3)Section 147Section 148Section 32(1)

…, thus, if any such amount become irrecoverable, the same would be, it is submitted, allowable as trading loss under section 28 of the Act. Attention in this regard is invited to the decision of the Delhi Bench of the Tribunal in the case of Minda HUF v. JCT: 101 ITD 191. In that case the Tribunal was pleased to hold that the CIT (A) erred in not allowing the claim of the assessee in respect of the advances written off which had become irrecoverable. The relevant observations of the Tribunal are reproduced herein-below for ready reference: “We have carefully considered the entire material on record and the rival…

ACIT, NEW DELHI vs. M/S. LANDBASE INDIA LTD., NEW DELHI

In the result, appeal of the assessee for assessment year 2011-12 is allowed

ITA 4849/DEL/2011[2005-06]Status: DisposedITAT Delhi26 Aug 2019AY 2005-06

Bench: Smt Beena A Pillai & Shri Prashant Maharishi

For Appellant: Shri Rohit Jain, AdvFor Respondent: Shri J. K. Mishra, CIT DR
Section 143(3)Section 147Section 148Section 32(1)

…, thus, if any such amount become irrecoverable, the same would be, it is submitted, allowable as trading loss under section 28 of the Act. Attention in this regard is invited to the decision of the Delhi Bench of the Tribunal in the case of Minda HUF v. JCT: 101 ITD 191. In that case the Tribunal was pleased to hold that the CIT (A) erred in not allowing the claim of the assessee in respect of the advances written off which had become irrecoverable. The relevant observations of the Tribunal are reproduced herein-below for ready reference: “We have carefully considered the entire material on record and the rival…

ZENRIBA ESTATES & INVESTMENTS P. LTD,MUMBAI vs. DCIT 7(3), MUMBAI

ITA 5105/MUM/2013[2010-11]Status: DisposedITAT Mumbai01 Nov 2017AY 2010-11

Bench: Shrir. C. Sharma, Am & Shri Sandeep Gosain, Jm आयकरअपीलसं./ I.T.A. No. 5105/Mum/2013 (निर्धारणवर्ा / Assessment Year: 2010-11)

For Appellant: Shri Jahangir Mistri&For Respondent: Shri V. Vidhyadhar
Section 28Section 36(1)(vii)Section 36(2)Section 37

…asset had been acquired, and therefore, the payment of advance was to be allowed as business loss Ld. AR also drawn our attention to the judgment passed by Hon’ble ITAT Delhi Bench in the case of Minda (HUF) Ltd. Vrs. Joint Commissioner of Income-tax (2006) 101 ITD 191 (Delhi) wherein it was held as under:- Section 37(1) of the Income-tax Act, 1961 - Business Expenditure - Allowability of - Assessment year 1997- 98 - During course of its business, assessee gave advances to vendors for supply of raw materials, etc - Said advances became ir-recoverable due to either material was not supplied or defective material…

ELITE INTERNATIONAL P.LTD,MUMBAI vs. ACIT CIR 6(2), MUMBAI

Appeal stands dismissed

ITA 3079/MUM/2014[2009-10]Status: DisposedITAT Mumbai07 Jun 2017AY 2009-10

Bench: Shri Saktijit Dey, Jm & Shri Manoj Kumar Aggarwal, Am

For Appellant: Vimal Punmiya, Ld. ARFor Respondent: Arvind Kumar, Ld. DR
Section 143(3)Section 36Section 36(2)

…wanagar Co-operative Bank Ltd. [Gujarat HC 54 Taxmann.com 28] (v) CIT Vs. Abdul Razak & Co. [Gujarat High Court 1982 136 ITR 825] (vi) ACIT Vs. Hi-Lines Pens Pvt. Ltd. [Delhi Tribunal ITA No. 2925/Delhi/2012] (vii) Minda (HUF) Limited Vs. JCIT [Delhi Tribunal 101 ITD 191] 5. Per contra, Ld. DR placed reliance on the findings of Ld. CIT(A) and contended that no deduction could be allowed against provisions for advances and therefore, not allowable. Moreover, the assessee’s case was not at all covered by the provisions of Sec. 36(i)(vii) as it was not a case of ‘debts being written off’ but a matter of claim of bu…