How many judgments cite TRF Ltd. v. CIT?

714 judgments on BharatTax cite TRF Ltd. v. CIT (323 ITR 397), spanning 2010 to 2026.

Which sections of the Income Tax Act does TRF Ltd. v. CIT come up under?

It is most often cited in judgments turning on Section 143(3), Section 36(1)(vii), Section 147, Section 14A, Section 36(2), Section 148.

TRF Ltd. v. CIT

323 ITR 397Supreme Court of India2010#71 most cited

What is TRF Ltd. v. CIT authority for?

For claiming deduction for bad debts under section 36(1)(vii) of the Income Tax Act, it is sufficient for the assessee to write off the debt as irrecoverable in its accounts, and it is not necessary to prove that the debt has actually become irrecoverable.

714

judgments rely on this decision, according to BharatTax’s citation analysis of 367,181 Indian tax judgments — from 2010 to 2026.

Also referred to as

TRF Ltd. v. CIT · section 36(1)(vii) · bad debts · deduction · irrecoverable · written off · assessee's accounts · income tax act

Also reported as

190 Taxmann 391230 CTR 14190 Taxmann.com 391

Sections most often in play

Section 143(3)Section 36(1)(vii)Section 147 Section 14A Section 36(2)Section 148 Section 40(a)(ia)Section 132

Issues it is cited on

section 36(2)section 36(1)(vii)business expediency section 36(1)section 36 commercial expediency revenue expenditure disallowance under section 14a capital expenditure section 28 section 115j section 14a

Judgments citing TRF Ltd. v. CIT

Uma Industries, Mehsana vs. ITO, Ward-2, Gandhinagar

In the result, appeal filed by the assessee is dismissed

ITA 342/AHD/2019[2013-14]Status: DisposedITAT Ahmedabad24 Aug 2022AY 2013-14

Bench: Ms. Suchitra Kamble & Shri Waseem Ahmeduma Industries V/S Income Tax Officer C/O. Utsav Selection, Main Ward – 2, Gandhinagar Bazar, Kukurvada, Tal. Vijapur, Dist. Mehsana (Appellant) (Respondent)

For Appellant: NoneFor Respondent: Shri V. K. Singh, Sr. D.R

Section 133(6)

…On question by the AO with regard to nature of debtor and details such as ledger copies, address, PAN and proof showing effort made for recovery. The assessee in response simply relied on the judgment of Hon’ble Supreme Court in case of TRF Ltd vs. CIT (2010) 323 ITR 397 (SC). 4.1 The AO found that the assessee has not provided the nature of transaction with debtor which in necessary for allowances or disallowances of claim of bad debts. As such the write off of those bad debts are only allowable which are arising out of the ordinary course of business. 4.2 The AO further held that to write off a debt it necess…

Aurobindo Pharma Ltd., Hyd, Hyderabad vs. DCIT, Central Circle-1(2), Hyd, Hyderabad

In the result, appeal of the assessee is allowed

ITA 786/HYD/2016[2009-10]Status: DisposedITAT Hyderabad18 Aug 2022AY 2009-10

Bench: Shri Rama Kanta Panda & Shri K.Narasimha Chary

For Appellant: Shri P.V.S.S.Prasad, ARFor Respondent: Shri Solgy Kottaram, CIT-DR

Section 143(3)Section 153ASection 36(1)(vii)Section 92C

…accepted by the Department, if it is written off as irrecoverable in the accounts in the year, the same has to be allowed as bad debt under section 36(1)(vii) of the Act, in terms of the decision of the Hon’ble Apex Court in the case of TRF Ltd Vs. CIT (2010) 323 ITR 397 (SC). For the same principle reliance is placed on the decisions reported in PCIT Vs. Shreno Ltd (2021) 127 taxmann.com 813 (Gujarat HC) and Pranava Electronics (P) Ltd Vs. DCIT (2021) 124 taxmann.com 242 (Karnataka HC). He also placed reliance on the decision reported in Harshad J Choksi Vs. CIT (2012) 349 ITR 250 (Bom) to support his point that…

Beiersdorf India (P) Ltd., Panaji vs. Income Tax Officer, Ward - 2(4), Panaji

In the result, appeal of assessee is partly allowed

ITA 337/PAN/2018[2014-15]Status: DisposedITAT Panaji17 Aug 2022AY 2014-15

Bench: Shri Chandra Mohan Garg & Shri Girish Agrawal

For Appellant: Sh D.E. Robinson, AdvocateFor Respondent: Sh Ranjan Kumar, CIT-DR

Section 28Section 36Section 43Section 43(5)

…t it is clear that once the debt is written-off as irrecoverable in the accounts of the assessee, it has to be allowed as bad debts. Learned Counsel for the Assessee submitted that as per the Judgment of Hon’ble Supreme Court in the case of TRF Ltd., vs., CIT 323 ITR 397 (SC) submitted that after 01.04.1989 it was not necessary for the assessee to establish that debt had become irrecoverable and it was enough if the bad debt was written- off as irrecoverable in the books. Therefore, the alternative plea of assessee treating the impugned amount as bad debt may kindly be allowed, if the main prayer of assessee is n…

Smt Asha Devi Poddar, Mumbai vs. ACIT 19(1), Mumbai

In the result, appeal filed by the assessee is treated as allowed for statistical purposes

ITA 687/MUM/2022[2014-15]Status: DisposedITAT Mumbai05 Aug 2022AY 2014-15

…sen to write off Rs.1,79,73,982/- as bad debts. He submitted that the assessee has duly complied with provisions of section 36(1)(vii) read with section 36(2) of the Act and hence claim of the assessee is allowable as bad debts as held in the case of TRF Ltd (323 ITR 397). He further submitted that the assessee has done trading on delivery basis and hence there is no reason for treating this transaction as speculative in nature. 8. The Learned AR also placed reliance on the decision rendered by Mumbai Bench of the ITAT in the case of DCIT Vs. Nirship Securities Pvt. Ltd. (ITA No. 6321/Mum/2019 and others dated 2…

M/S. Weikfield Products Corporation LLP, Pune vs. Pr. Commissioner of Income-Tax -4, Pune

Appeal is dismissed in above terms

ITA 760/PUN/2019[2014-15]Status: DisposedITAT Pune21 Jul 2022AY 2014-15

Bench: Shri S.S. Godara & Dr. Dipak P. Ripoteनिर्धारण वषा / Assessment Year : 2014-15 M/S. Weikfield Products Vs. Pr.Cit-4, Pune Corporation Llp 3A, 3Rd Floor, Vascon Weikfield Chambers, Shri Satpal Malhotra Marg, Nagar Road, Pune – 411014 Pan : Aabfw2289C Appellant Respondent

Section 143(3)Section 2Section 263Section 43(5)

…merit since the case records speak otherwise. First of all comes the assessee‟s corresponding ledger account regarding M/s. Anand Rathi Sundry Debtors at page 69, wherein there is no actual write off forming a mandatory condition as per TRF Ltd vs. CIT (2010) 323 ITR 397 (SC). This is indeed coupled with the fact that the Revenue has successfully invited our attention to the assessee‟s paper book page(s) 61 onwards wherein the corresponding contract notes; both purchases and sales, are dated 25.06.2013 not involving actual delivery of the commodity(ies) concerned. Mr. Meena next took us to page 71 in the assessee…

Ibm India Pvt. Ltd., Bangalore vs. DCIT, Bangalore

In the result appeal filed by assessee stands allowed

ITA 1151/BANG/2009[2002-03]Status: DisposedITAT Bangalore30 Jun 2022AY 2002-03

Bench: Shri. Chandra Poojari & Smt. Beena Pillaiassessment Year : 2002-03 M/S. Ibm India Pvt. Ltd., The Deputy No. 12, Subramanya Commissioner Of Arcade, Income Tax, Bannerghatta Road, Circle 11 (1), Bangalore – 560 029. Bangalore. Vs. Pan: Aaaci4403L Appellant Respondent Assessee By : Shri Sharath Rao, Advocate Revenue By : Shri Vilas V Shinde, Cit Dr Date Of Hearing : 30-06-2022 Date Of Pronouncement : 30-06-2022 Order Per Beena Pillaipresent Appeal Arises Out Of The Dated 3/11/2020 Passed By Hon’Ble Karnataka High Court In Ita No.392/2011. Hon’Ble High Court Admitted The Following Question Of Law Vide Order Dated 28/03/2012: “(I) Whether The Tribunal Was Correct In Holding That Whether The Appellate Authority Were Correct In Holding That Maintenance Of Separate Accounts For Stp Units & Non Stp Units Was Only Directory & Not Mandatory In Accordance With Rbi Conditions, Government Notification & Income Tax Act? (Ii) Whether The Appellate Authority Were Correct In Holding That Payments Made To Sub Contractors Who Have Separately Exported & Have Been Issued Foreign Inward Remittance Certificate & Have Also Claimed 10A Deduction Will Also Be Entitled To Double Deduction Under Section 10A Of The Act In Hands Of The Assessee?

For Appellant: Shri Sharath Rao, AdvocateFor Respondent: Shri Vilas V Shinde, CIT DR

Section 10A

…al was correct in holding that the assessee is entitle for write off of a sum of Rs.12,72,91,172/- as bad debts before the debt becoming bad merely on the write off of the assessee without following the law laid down by the Apex Court in the case of TRF Ltd., 323 ITR 397 and recorded a perverse finding? (v) Whether the tribunal was correct in allowing the write off as bad debt in the facts and circumstances of the present case, when invoices were raised few months prior to the write off of the debtors were reputed companies including Government undertakings and business was continued with the debtors by the asses…

Axis Cades Aerospace Infrastructure Private Limited, Bangalore vs. Principal Commissioner of Income Tax Bangalore-1, Bangalore

In the result, the appeal by the assessee is dismissed

ITA 777/BANG/2017[2012-13]Status: DisposedITAT Bangalore27 Jun 2022AY 2012-13

Bench: Shri N.V. Vasudevan, Vice Preseident & Shri Padmavathy Sassessment Year : 2012-13

For Appellant: Shri Sheetal Borkar, AdvocateFor Respondent: Shri Praveen Karanth, CIT(DR)(ITAT), Bengaluru

Section 143(2)Section 263Section 36(1)(vii)

…cepting the returned income. He therefore submitted that the order of the AO is not erroneous or prejudicial to the interests of the revenue and prayed for quashing of the impugned order. He relied on the Supreme Court judgment in the case of TRF Ltd. v. CIT, 323 ITR 397 (SC). 9. The ld. DR, on the other hand, argued that mere submission of details by the assessee does not amount to verification by the AO. The AO did not verify the details furnished by the assessee and passed a very cryptic order. In this regard, he relied on the following decisions:- (i) JNS Instruments Ltd. v. PCIT [ITA No.1479/Del/2017 dated…

M/S. Mackintosh Burn Ltd., Kolkata vs. DCIT, Circle - 11(2), Kolkata

In the result, both the appeals filed by the assessee for AYs

ITA 210/KOL/2022[2013-14]Status: DisposedITAT Kolkata22 Jun 2022AY 2013-14

Bench: Sri Manish Borad & Sri Sonjoy Sarma

Section 139(1)Section 143(2)Section 250Section 36(1)(va)Section 43B

…IN THE INCOME TAX APPELLATE TRIBUNAL KOLKATA ‘B’ BENCH, KOLKATA Before SRI MANISH BORAD, ACCOUNTANT MEMBER & SRI SONJOY SARMA, JUDICIAL MEMBER I.T.A. Nos.: 209 & 210/Kol/2022 Assessment Year: 2012-13 & 2013-14 Mackintosh Burn Limited........................................Appellant [PAN: AACCM 2160 J] Vs. DCIT, Circle-11(2), Kolkata...................................Respondent Appearances by: Dr. Somnath Ghosh, FCA, appeared on behalf of the Assessee. Smt. Ranu Biswas, Addl. CIT(D/R), appeared on behalf of the Revenue. Date of concluding the hearing : June 14th, 2022 Date of pronouncing the order : June 22nd, 20…

M/S. Mackintosh Burn Ltd., Kolkata vs. DCIT, Circle - 11(2), Kolkata

In the result, both the appeals filed by the assessee for AYs

ITA 209/KOL/2022[2012-13]Status: DisposedITAT Kolkata22 Jun 2022AY 2012-13

Bench: Sri Manish Borad & Sri Sonjoy Sarma

Section 139(1)Section 143(2)Section 250Section 36(1)(va)Section 43B

Air India Ltd, Mumbai vs. Addl CIT RG 5(1), Mumbai

In the result, appeal of the assessee is allowed

ITA 3383/MUM/2014[2009-10]Status: DisposedITAT Mumbai06 Jun 2022AY 2009-10

Bench: Shri Amarjit Singh () & Kavitha Rajagopal () M/S Air India Ltd Vs Addl.Commissioner Of Income-Tax (Formerly Known As National Range-5(1), Mumbai Aviation Co. Of India Ltd) Finance Building, Old Airport Kalina, Santacruz (E), Mumbai-400 029 Pan : Aaccn6194P Appellant Respondent

Section 143(3)

…ee’s subsidiaries and Ld.CIT(A) confirmed the addition made by the Assessing Officer. 5. Before us, the Ld.AR contended that the assessee has written off the said amount even in the previous year and was covered by the decision of Apex Court in TRF Ltd vs CIT 323 ITR 397 (SC). The Ld.DR vehemently argued that such debt was recoverable and on the other hand, relied on the order of the lower authorities. 6. Having heard both the Ld.representatives and perused the material on record, we are of the considered opinion that such dues were recoverable by the assessee from Airline Allied Services Ltd on account of reimbu…

K Patel International, Ankleshwar vs. ACIT, Circle-2, Bharuch

In the result, this appeal of the assessee is allowed

ITA 187/SRT/2020[2013-14]Status: DisposedITAT Surat01 Jun 2022AY 2013-14

Bench: Shri Pawan Singh & Dr. Arjun Lal Sainik Patel International, A.C.I.T., Residential Plot 64, Gidc, Circle-2, Vs. Ankleshwar-393002. Bharuch. Pan No. Aacfk 7262 Q Appellant/ Assessee Respondent/ Revenue

Section 254(1)Section 28Section 36

…IN THE INCOME TAX APPELLATE TRIBUNAL, SURAT BENCH, SURAT BEFORE SHRI PAWAN SINGH, JUDICIAL MEMBER AND DR. ARJUN LAL SAINI, ACCOUNTANT MEMBER K Patel International, A.C.I.T., Residential Plot 64, GIDC, Circle-2, Vs. Ankleshwar-393002. Bharuch. PAN No. AACFK 7262 Q Appellant/ assessee Respondent/ revenue Assesseerepresented by Shri Surendra Modiani, CA Respondent represented by Shri Abhishek Gautam, Sr.DR Date of hearing 01/06/2022 Date of pronouncement 01/06/2022 Order under section 254(1) of Income Tax Act PER: PAWAN SINGH, JUDICIAL MEMBER: 1. This appeal by the assessee is directed against the order of learned…

M/S. Salarpuria Properties Pvt. Ltd., Kolkata vs. DCIT, Circle - 1, Kolkata

In the result, assessee’s appeal in ITA No

ITA 2094/KOL/2017[2010-11]Status: DisposedITAT Kolkata10 May 2022AY 2010-11

Bench: Shri Sanjay Garg & Shri Rajesh Kumar]

Section 115JSection 234CSection 801Section 80I

…f Rs. 2,36,454/- which were apparently arising in normal course of business or pertaining to amounts receivable and therefore the assessee is entitled to charge the same against the profits during the year in terms of ratio laid down in T.R.F Ltd. reported in 323 ITR 397 (SC). We therefore do not find any infirmity in the order of Ld. CIT(A) and accordingly ground no. 3 raised by the revenue is dismissed. 8.13. The issue raised in ground no. 4 by the revenue is against the deletion of addition of Rs. 72,93,646/- as made by the AO on account of on money received upon sale of flats. 8.14. Facts in brief are that…

Hosch Equipment India Ltd., Kolkata vs. ACIT, Cir.-10(2), Kolkata

In the result, the appeal of the assessee is allowed

ITA 395/KOL/2020[2014-15]Status: DisposedITAT Kolkata09 May 2022AY 2014-15

Bench: Shri Rajpal Yadav, Vice-(Kz) & Shri Manish Borad

Section 143(2)

…ITA No. 395/KOL/2020 A.Y. 2014-2015 Hosch Equipment India Limited IN THE INCOME TAX APPELLATE TRIBUNAL, KOLKATA ‘A’ BENCH, KOLKATA Before Shri Rajpal Yadav, Vice-President (KZ) & Shri Manish Borad, Accountant Member I.T.A. No. 395/KOL/2020 Assessment Year: 2014-2015 Hosch Equipment India Limited,.........................................................Appellant 4th Floor, Gariahat Mall, 13, Jamir Lane, Kolkata-700019 [PAN: AAACH6640J] -Vs.- Assistant Commissioner of Income Tax,..........................................Respondent Circle-10(2), Kolkata, Aayakar Bhawan, 3 rd Floor, P-7, Chowringhee Square, Ko…

Tamil Nadu Water Investment Company Limited, Chennai vs. ACIT, Chennai

In the result, the appeal filed by the Revenue is allowed for statistical purposes and the appeal filed by the assessee is partly allowed

ITA 696/CHNY/2017[2012-2013]Status: DisposedITAT Chennai06 May 2022AY 2012-2013

Bench: Shri V. Durga Rao & Shri Manoj Kumar Aggarwalआयकर अपील सं./I.T.A. No.694/Chny/2017 िनधा"रण वष"/Assessment Year: 2012-13 The Assistant Commissioner Of Vs. M/S. Tamil Nadu Water Investment Co. Ltd., 1St Floor, Poly Hose Towers, Income Tax, Corporate Circle 3(1), New Block, 4Th Floor, 121, Mahatma No. 86, Mount Road, Guindy, Gandhi Road, Nungambakkam, Chennai – 32. Chennai 600 034. [Pan: Aabct8153B] (अपीलाथ"/Appellant) (""थ"/Respondent) आयकर अपील सं./I.T.A. No.696/Chny/2017 िनधा"रण वष"/Assessment Year: 2012-13 M/S. Tamil Nadu Water Investment Vs. The Assistant Commissioner Of Co. Ltd., 1St Floor, Poly Hose Towers, Income Tax, Corporate Circle 3(1), No. 86, Mount Road, Guindy, Chennai 600 034. Chennai – 32. (अपीलाथ"/Appellant) (""थ"/Respondent) Department By : Shri Ar V Sreenivasan, Addl. Cit Assessee By : Shri R. Viswanathan, C.A. सुनवाई की तारीख/ Date Of Hearing : 18.04.2022 घोषणा की तारीख /Date Of Pronouncement : 06.05.2022 आदेश /O R D E R Per V. Durga Rao: Both The Cross Appeals Filed By The Revenue & The Assessee Are Directed Against The Order Of The Ld. Commissioner Of Income Tax (Appeals)13, Chennai Dated 27.12.2016 Relevant To The Assessment Year 2012-13. 2

For Appellant: Shri R. Viswanathan, C.AFor Respondent: Shri AR V Sreenivasan, Addl. CIT

Section 14A

…being aggrieved the assessee is in appeal before the 12 I.T.A. Nos.694 & 696/Chny/17 Tribunal. By reiterating the submissions as made before the ld.CIT(A) as well as filing copy of the judgement of the Hon’ble Supreme Court in the case of T.R.F. Ltd. v. CIT 323 ITR 397, the ld. Counsel for the assessee has prayed for following the above judgement. 5.3 On the other hand, the ld. DR strongly supported the orders of authorities below. 5.4 We have heard the rival contentions. Against the disallowance of bad debt written off, the assessee has submitted before the ld. CIT(A) that the Assessing Officer has not consi…

ACIT, Chennai vs. Tamil Nadu Water Investment Co. Ltd., Chennai

In the result, the appeal filed by the Revenue is allowed for statistical purposes and the appeal filed by the assessee is partly allowed

ITA 694/CHNY/2017[2012-13]Status: DisposedITAT Chennai06 May 2022AY 2012-13

For Appellant: Shri R. Viswanathan, C.AFor Respondent: Shri AR V Sreenivasan, Addl. CIT

Section 14A

Pranav Shantikumar Gandhi, Mumbai vs. ACIT Ward 19 (2), Mumbai

In the result, the appeal is allowed

ITA 6884/MUM/2019[2014-15]Status: DisposedITAT Mumbai06 May 2022AY 2014-15

Section 143(3)Section 36(1)(vii)

…d and duly considered facts of the case in the light of applicable legal position. 8. I find that firstly it is only elementary that while claiming the deduction in respect of bad debts, as held by Hon’ble Supreme Court in the case of TRF Ltd. vs CIT [(2010) 323 ITR 397 Assessment Year: 2014-15 Page 4 of 4 (SC)], it is not necessary that the amount in question is conclusively held to be unrecoverable. The write off per se, as long as it is bonafide, is sufficient to claim the bed debt as deduction. It is also not in dispute that the proceedings against NSEL were in progress in various courts. The bonafide of the…

Canara Housing Development Company, Bangalore vs. Deputy Commissioner of Income Tax, Central Circle - 2(2), Bangalore

In the result, the appeal filed by the assessee is treated as allowed for statistical purposes

ITA 976/BANG/2019[2013-14]Status: DisposedITAT Bangalore29 Apr 2022AY 2013-14

Bench: Shri B. R. Baskaran & Smt. Beena Pillaiassessment Year: 2013-14

For Appellant: Shri Ramakrishnan, A.RFor Respondent: Shri Sumer Singh Meena, D.R

…ller advances of less than Rs.50.00 lakhs on the reasoning that these kind of write off is incidental to the business. 3. Before Ld. CIT(A), the assessee placed its reliance on the decision rendered by Hon’ble Supreme Court in the case of TRF Limited Vs. CIT 323 ITR 397 and contended that the amount written off as bad should be allowed as deduction. However, the Ld. CIT(A) took the view that writing off of bad debt is not an empty formality and assessee cannot convert any live amount to bad debt only on the basis of technical rule of write off. The Ld. CIT(A) further observed that the assessee has not produced a…

ACIT, Circle- 30(1), New Delhi vs. Syed Habibr Rehman, New Delhi

In the result, the Revenue’s appeal is dismissed

ITA 7597/DEL/2018[2014-15]Status: DisposedITAT Delhi25 Apr 2022AY 2014-15

Bench: Shri G.S. Pannu, Hon’Ble & Ms. Astha Chandraasstt. Year : 2014-15

For Appellant: Shri R.K. Gupta, AdvocateFor Respondent: Shri Umesh Takyar, Sr. DR

Section 133(6)Section 36(1)(vii)Section 36(2)

…ce to prove that the impugned sum has been written off in his books of account. He relied on Hon’ble Delhi High Court’s decision in the case of CIT vs. Autometers Ltd. (supra) and judgment of the Hon’ble Supreme Court in the case of T.R.F. Ltd. vs. CIT (2010) 323 ITR 397 (SC) as also on CBDT’s Circular No. 12/2016 dated 30th May, 2016. 8. We have given careful thought to the rival submissions and perused the material on record. We are of the opinion that the Revenue will not succeed. The Ld. AO has been candid enough to observe that the assessee has written off bad debt to the tune of Rs. 1,50,00,000/-. His prime…

Pranava Electronics P Ltd, Bangalore vs. Deputy Commissioner of Income Tax, Circle-12(2), Bangalore

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

ITA 415/BANG/2015[2010-11]Status: DisposedITAT Bangalore06 Apr 2022AY 2010-11

Bench: Shri Chandra Poojari & Smt. Beena Pillaiassessment Year: 2010-11

For Appellant: Shri K.R. Pradeep, Advocate and Ms. Girija, AdvocateFor Respondent: Shri Priyadarshini Mishra, Addl. CIT

Section 115JSection 14Section 14ASection 234BSection 37(1)

…"to carryon the business of education and training in technical and other fields'. (b) Whether in the facts and circumstances of the case, tribunal erred in denying the bad debts written off as allowable deductions in view of the decision in TRF Ltd. v. CIT, 323 ITR 397? Page 3 of 21 (c) Whether in the facts and circumstances of the case, the tribunal erred in not taking into consideration the evidences filed by the assessee to substantiate that the interest amount was offered for tax in the earlier years and portion of the debt was taken for computing the income of the assessee. (d) Whether in the facts and ci…

ACIT (Central Ujjain, Ujjain vs. M/S Arihant Future and Commodities Ltd, Indore

ITA 734/IND/2019[2016-17]Status: DisposedITAT Indore31 Mar 2022AY 2016-17

Bench: Shri Mahavir Prasad, Judicialmember & Shri Manish Boradvirtual Hearing &

Section 143(3)Section 147Section 36Section 36(1)(ii)Section 37(1)Section 68Section 69C

…2014-15 dated 05.02.2019. 4.4.8 Therefore, in view of the above discussion and also in view of the above judicial cases including that of the Honourable Jurisdictional ITAT and also that of the Honourable Apex Court in the case of M/s TRF Ltd. V/s CIT (2010) 323 ITR 397 (SC) and also circular no. 12/2016 issued by the Central Board of Direct Taxes, the disallowance made by the AO on account of bad debts amounting to Rs. 1,93,91,871/- is Deleted. Therefore, appeal on this ground is Allowed. 10. From perusal of the above findings of the Ld. CIT(A), we find that there is no dispute that the amount due from NSEL wa…