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

R.J.Trade Wings Pvt. Ltd., Mumbai vs. ACIT- Circle- 2(3)(2), Mumbai

In the result, the appeal is partly allowed

ITA 5770/MUM/2018[2015-16]Status: DisposedITAT Mumbai30 Sept 2019AY 2015-16

Bench: Shri C.N. Prasad () & Shri N.K. Pradhan () Assessment Year: 2015-16 M/S R.J. Trade Wings Pvt. Assistant Commissioner Of Income Ltd. 18/20, Dubash Marg, Vs. Tax, Circle-2(3)(2), Aayakar Kala Ghoda, Fort, Mumbai- Bhavan, M.K. Marg, Mumbai- 400020. 400020. Pan No. Aabcr1467J Appellant Respondent

For Appellant: Ms. Aniket Shet, ARFor Respondent: Mrs. Jothi Lakshmi Nayak, DR

Section 143(3)Section 154Section 36(1)(va)Section 36(2)Section 43B

…IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCH “D” MUMBAI BEFORE SHRI C.N. PRASAD (JUDICIAL MEMBER) AND SHRI N.K. PRADHAN (ACCOUNTANT MEMBER) Assessment Year: 2015-16 M/s R.J. Trade Wings Pvt. Assistant Commissioner of Income Ltd. 18/20, Dubash Marg, Vs. Tax, Circle-2(3)(2), Aayakar Kala Ghoda, Fort, Mumbai- Bhavan, M.K. Marg, Mumbai- 400020. 400020. PAN No. AABCR1467J Appellant Respondent Assessee by : Ms. Aniket Shet, AR Revenue by : Mrs. Jothi Lakshmi Nayak, DR Date of Hearing : 23/09/2019 Date of pronouncement : 30/09/2019 ORDER PER N.K. PRADHAN, AM This is an appeal filed by the assessee. The relevan…

Edge Steels Pvt. Ltd., Mumbai vs. ITO - WD -12(2)(2), Mumbai

The appeal of the assessee is allowed for statistical purpose in terms of our aforesaid observations

ITA 3332/MUM/2018[2012-13]Status: DisposedITAT Mumbai20 Sept 2019AY 2012-13

Bench: Shri M. Balaganesh & Shri Ravish Soodm/S Edge Steels Pvt. Ltd. Income Tax Officer-Wd-12(2)(2) 404, Ram Krishna Chambers, Room No. 146(1), 1St Floor, 5, Linking Road, Khar (West) Vs. Aayakar Bhawan, M.K. Road, Mumbai – 400 052 Mumbai – 400020

For Appellant: Shri M. Balasubramanian, A.RFor Respondent: Shri Amit Pratap Singh, D.R

Section 143(1)Section 143(2)Section 143(3)

…he account of the said party. 7. We have given a thoughtful consideration to the issue under consideration in the backdrop of the facts available on record. Admittedly, as per the judgment of the Hon’ble Supreme Court in the case of T.R.F. Ltd, Vs. CIT (2010) 323 ITR 397 (SC), after 01.04.1989, it is not necessary for the assessee to establish that the debt, in fact, had become irrecoverable. It was observed that if the bad debt is written off as irrecoverable in the accounts of the assessee, the same would duly suffice for entitling it to claim deduction of the same under Sec.36(1)(vii) of the Act. In our consid…

Assistant Commissoner of Income-Tax vs. Thermax Ltd., Pune

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

ITA 714/PUN/2014[2006-07]Status: DisposedITAT Pune13 Sept 2019AY 2006-07

Bench: Shri R.S. Syal & Shri S.S. Viswanethra Raviआयकर अपील सं. / Ita No.509/Pun/2014 िनधा"रण वष" / Assessment Year : 2006-07 Thermax Limited, Vs. Dcit, Circle-10, 14, Mumbai Pune Road, Pune Wakdewadi, Pune – 411 003 Pan : Aaact3910D Appellant Respondent आयकर अपील सं. / Ita No.714/Pun/2014 िनधा"रण वष" / Assessment Year : 2006-07

Section 131(1)Section 132Section 133A

…30. Having heard both the sides and gone through the relevant material on record, it is found as an admitted position that the assessee, in fact, wrote off the amount of bad debts in its books of account. The Hon’ble Supreme Court in TRF Ltd. Vs. CIT (2010) 323 ITR 397 (SC) has held that after 01-04-1989, the assessee is not Thermax Ltd., required to establish that the debt had became bad in the previous year. It was further held that the deduction has to be allowed on a mere write off. Since in the instant case, admittedly the assessee wrote off the amount in its books of account and it is not the case of t…

Thermax Limited, Pune vs. Deputy Commissioner of Income-Tax

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

ITA 509/PUN/2014[2006-07]Status: DisposedITAT Pune13 Sept 2019AY 2006-07

Section 131(1)Section 132Section 133A

Remi Sales and Engineering Limited, Mumbai vs. ACIT, Circle 13(3)(1), Mumbai

In the result, appeal of the assessee is allowed

ITA 3650/MUM/2018[2014-15]Status: DisposedITAT Mumbai06 Sept 2019AY 2014-15

Bench: Shri C.N. Prasad, Hon'Ble & Shri Rajesh Kumar, Hon'Ble

For Appellant: Shri Shankarlal JainFor Respondent: Shri D.G. Pansari

Section 143(3)Section 36(2)

…unt has been written off as bad debts in its books of accounts it meets the requirement of section 36(2) of the Act and therefore should be allowed as deduction. He strongly relied on the decision of the Hon'ble Supreme Court in the case of T.R.F Ltd. v. CIT [323 ITR 397], wherein it has been held that it is not necessary for the assessee to establish that the debt, in fact, has become irrecoverable. It has been held that it is enough if the bad debts are written off as irrecoverable in the accounts of the assessee. 5. Ld. DR vehemently supported the orders of the authorities below. 6. We have heard the rival s…

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

…the appeal in the appellate proceedings in Income Tax Appellate Tribunal (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 pa…

Deputy Commissioner of Income Tax, Circle-2(1)(2), Surat vs. Shantai Exim Ltd., Ahmedabad

In the result, ITA.No.436/SRT/2018 of the Department is dismissed

ITA 436/SRT/2018[2012-13]Status: DisposedITAT Surat27 Aug 2019AY 2012-13

Bench: Shri Bhavnesh Saini & Shri O.P. Meena

For Appellant: Shri Ketan Shah And Shri Aman Shah, AdvocatesFor Respondent: Shri Sriniwas T. Bidani, CIT-D.R

Section 133A

…other hand Ld. D.R. merely relied upon the Orders of the authorities below. 19. We have considered the rival submissions and do not find any justification to sustain even the part addition. The Hon’ble Supreme Court in the case of TRF Limited vs. CIT [2010] 323 ITR 397 (SC) held as under : “After the amendment of Section 36(1)(vii) of the Income tax Act, 1961, with effect from April 1, 1989, in order to obtain a deduction in relation to bad debts, it is not necessary for the assessee to establish that the debt, in fact, has become irrecoverable; it is enough if the bad 38 ITA.Nos.273 & 436/SRT/2018 M/s. Shant…

Shantai Exim Ltd., Ahmedabad vs. Deputy Commissioner of Income Tax, Circle-2(1)(2), Surat

In the result, ITA.No.436/SRT/2018 of the Department is dismissed

ITA 273/SRT/2018[2012-13]Status: DisposedITAT Surat27 Aug 2019AY 2012-13

Bench: Shri Bhavnesh Saini & Shri O.P. Meena

For Appellant: Shri Ketan Shah And Shri Aman Shah, AdvocatesFor Respondent: Shri Sriniwas T. Bidani, CIT-D.R

Section 133A

M/S Pradhan Engineering Enterprises Pvt. Ltd., Dewas vs. The ACIT 1(1), Ujjain

In the result, the appeal of the Assessee for A

ITA 934/IND/2016[2012-13]Status: DisposedITAT Indore14 Aug 2019AY 2012-13

Bench: Shri Kul Bharat & Shri Manish Borad

Section 115JSection 143(2)Section 143(3)

…आयकर अपील"य अ"धकरण, इ"दौर "यायपीठ, इ"दौर IN THE INCOME TAX APPELLATE TRIBUNAL INDORE BENCH, INDORE BEFORE SHRI KUL BHARAT, JUDICIAL MEMBER AND SHRI MANISH BORAD, ACCOUNTANT MEMBER ITA Nos.933 & 934/Ind/2016 Assessment Years: 2008-09 & 2012-13 M/s Pradhan Engineering ACIT 1(1), बनाम/ Enterprises Pvt. Ltd. Ujjain Vs. 36/37 Ujjain Road, Dewas (Appellant) (Revenue) PAN: AAACP9729J Appellant by Shri Anil Kamal Garg & Arpit Gour CA’s Revenue by Smt. Vineeta Dube Sr. DR Date of Hearing: 25.07.2019 Date of Pronouncement: 14.08.2019 आदेश / O R D E R PER MANISH BORAD, A.M: These two appeals at the instance of Assessee…

M/S Pradhan Engineering Enterprises Pvt. Ltd., Dewas vs. The ACIT 1(1), Ujjain

In the result, the appeal of the Assessee for A

ITA 933/IND/2016[2008-09]Status: DisposedITAT Indore14 Aug 2019AY 2008-09

Bench: Shri Kul Bharat & Shri Manish Borad

Section 115JSection 143(2)Section 143(3)

Deekay Iron and Steel Private Limited, Mumbai vs. Income Tax Officer, Ward-3, Panvel

In the result, appeal of the assessee is allowed for statistical purpose

ITA 4496/MUM/2017[2011-12]Status: DisposedITAT Mumbai08 Aug 2019AY 2011-12

Bench: Shri C.N. Prasad, Hon'Ble & Shri M. Balaganesh, Hon'Blem/S. Deekay Iron & Steel Pvt. Ltd., V. Income Tax Officer B-503, Dheeraj Diamond Ward No. -3 Chincholi Bunder, Malad(W) Panvel Mumbai – 400 064 Pan: Aaccd3168P (Appellant) (Respondent) Assessee By : Shri Dharmesh Shah Department By : Shri Chaitanya Anjaria

For Appellant: Shri Dharmesh ShahFor Respondent: Shri Chaitanya Anjaria

…ekay Iron & Steel Pvt. Ltd., offered as income in earlier years and since they were written off, in this year as bad debts they have to be allowed as deduction. Reliance was placed on the decision of the Hon'ble Supreme Court in the case of T.R.F Ltd. v. CIT [323 ITR 397]. However, the Ld.CIT(A) sustained the disallowance to the extent of ₹.10,28,319/- observing that the assessee has shut down its regular business activities and had earned only interest income. Assessee in earlier years was carrying on its regular business activities with crores of turnover but during this year the business activity of the assess…

Icici Securities Ltd ( Earlier Known As Icici Brokerage Services Ltd), Mumbai vs. Addl CIT RG 4(1), Mumbai

Appeal of the assessee is allowed and that of department is dismissed, as above

ITA 5789/MUM/2010[2006-07]Status: DisposedITAT Mumbai26 Jul 2019AY 2006-07

Bench: Shri G.S. Pannu & Shri Ram Lal Negi: A.Y : 2006-07

For Appellant: Ms. Aarti VissanjiFor Respondent: Shri Neil Philip

Section 10(34)Section 143(3)Section 14ASection 234BSection 40A(2)(b)

…ired to give any justification for writing-off the bad debt and nor is he required to establish that the debt has actually become bad. In this regard, reliance has been placed on the decision of the Hon’ble Supreme Court in the case of T.R.F. Limited vs. CIT, 323 ITR 397 (SC). It was further pointed out that in assessment year 2004-05, similar matter had travelled to the Tribunal, and the claim has been allowed. 27. On the other hand, the ld. DR has defended the stand of the Assessing Officer by reiterating that the justification for write-off has not been spelt out and no efforts have been shown to be made for…

Deputy Commissioner of Income-Tax vs. M/S. Tasty Bites Eatables Ltd., Pune

In the result, the appeal of the Revenue is dismissed

ITA 626/PUN/2016[2011-12]Status: DisposedITAT Pune24 Jul 2019AY 2011-12

For Appellant: Shri Arijit Chakravarty &For Respondent: Shri Manoj Kumar Gautam

Section 92CSection 92C(2)

…at the assessee continues to have considered in transactions with the said debtor. However, there is no dispute on the fact the amounts were written off in the books of the assessee. The assessee relied heavily on the judgement in the case of TRF Ltd. vs. CIT 323 ITR 397. The DRP confirmed the said disallowance. On hearing both the sides on this issue, we find that the claim of the assessee is proper. We find no violation by the assessee in claiming the said bad debts. The assessee has strength of the said Apex Court’s judgement in the case of TRF Ltd. (supra). We accordingly allow the claim of bad debts in favou…

Tasty Bite Eatables Ltd., Pune vs. Deputy Commssioner of Income-Tax

In the result, the appeal of the Revenue is dismissed

ITA 449/PUN/2016[2011-12]Status: DisposedITAT Pune24 Jul 2019AY 2011-12

For Appellant: Shri Arijit Chakravarty &For Respondent: Shri Manoj Kumar Gautam

Section 92CSection 92C(2)

ITO, New Delhi vs. M/S. Niit Smartserve Ltd., New Delhi

In the result, the appeal of the Revenue on both the grounds is dismissed

ITA 2160/DEL/2017[2011-12]Status: DisposedITAT Delhi12 Jul 2019AY 2011-12

Bench: Sh. Bhavnesh Sainidr. B. R. R. Kumarita No. 2160/Del/2017 : Asstt. Year : 2011-12 Income Tax Officer, Vs M/S Niit Smartserve Ltd., 8, Balaji Estate, 1St Floor, Guru Ravi Das Ward-18(3), New Delhi Marg, Kalkaji, New Delhi-110019 (Appellant) (Respondent) Pan No. Aabcn4598E Assessee By : Sh. Gaurav Jain, Adv. Revenue By : Ms. Rinku Singh, Sr. Dr Date Of Hearing: 11.07.2019 Date Of Pronouncement: 12.07.2019 Order Per Dr. B. R. R. Kumar:

For Appellant: Sh. Gaurav Jain, AdvFor Respondent: Ms. Rinku Singh, Sr. DR

Section 37(1)

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCHES ‘E’, NEW DELHI Before Sh. Bhavnesh Saini, Judicial Member Dr. B. R. R. Kumar, Accountant Member ITA No. 2160/Del/2017 : Asstt. Year : 2011-12 Income Tax Officer, Vs M/s NIIT Smartserve Ltd., 8, Balaji Estate, 1st Floor, Guru Ravi Das Ward-18(3), New Delhi Marg, Kalkaji, New Delhi-110019 (APPELLANT) (RESPONDENT) PAN No. AABCN4598E Assessee by : Sh. Gaurav Jain, Adv. Revenue by : Ms. Rinku Singh, Sr. DR Date of Hearing: 11.07.2019 Date of Pronouncement: 12.07.2019 ORDER Per Dr. B. R. R. Kumar, Accountant Member: The Revenue has raised the following grounds: “1.…

ITO, New Delhi vs. M/S. Nilgiri Financial Consultants Ltd., New Delhi

In the result, the appeal of the revenue in ITA No

ITA 4/DEL/2017[2012-13]Status: DisposedITAT Delhi04 Jul 2019AY 2012-13

Bench: Shri N.K. Billaiya & Ms. Suchitra Kamble[A.Y 2012-13]

For Appellant: Shri Gautam Jain, AdvFor Respondent: Ms. Rinku Singh, Sr. DR

Section 36(1)(vii)

…1 IN THE INCOME TAX APPELLATE TRIBUNAL, DELHI ‘E’ BENCH, NEW DELHI BEFORE SHRI N.K. BILLAIYA, ACCOUNTANT MEMBER, AND MS. SUCHITRA KAMBLE, JUDICIAL MEMBER [A.Y 2012-13] The I.T.O Vs. M/s Nilgiri Financial Consultants Ltd M -62 & 63, 1st Floor, Ward – 18 (3) New Delhi Connaught Place, New Delhi PAN No: AABCD 0033 C [Appellant] [Respondent] Date of Hearing : 04.07.2019 Date of Pronouncement : 04.07.2019 Assessee by : Shri Gautam Jain, Adv Shri Lalit Mohan, CA Revenue by : Ms. Rinku Singh, Sr. DR ORDER PER N.K. BILLAIYA, ACCOUNTANT MEMBER: With this appeal by the Revenue has challenged the correct…

DCIT Cir 3(1), Mumbai vs. Icici Bank Ltd, Mumbai

ITA 5191/MUM/2009[2004-05]Status: DisposedITAT Mumbai03 Jul 2019AY 2004-05

Bench: Hon’Ble Shri Saktijit Dey, Jm & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकरअपील सं./ I.T.A. No.5191/Mum/2009 (िनधा"रण वष" / Assessment Year: 2004-05) Dcit-Circle 3(1) Icici Bank Limited बनाम Room No.607, 6Th Floor नाम/ नाम नाम Icici Bank Towers Aaykar Bhavan Bandra-Kurla Complex Vs. Mumbai-400 020. Mumbai-400 051. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaaci-1195-H (अपीलाथ" / Appellant) (ू"यथ" / Respondent) : & C.O. No.127/Mum/2010 [Arising Out Of I.T.A. No.5191/Mum/2009] (िनधा"रण वष" / Assessment Year: 2004-05) Icici Bank Limited Dcit-Circle 3(1) बनाम नाम नाम/ नाम Room No.607, 6Th Floor Icici Bank Towers Bandra-Kurla Complex Aaykar Bhavan Vs. Mumbai-400 051. Mumbai-400 020. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaaci 1195 H (""ा"ेप ""ा"ेप ""ा"ेप /Cross Objector) ""ा"ेप (ू"यथ" / Respondent) :

For Appellant: Ms. Aarti Vissanji-Ld. ARFor Respondent: Shri P.C. Chhotaray -Ld.DR

Section 10Section 143(2)Section 143(3)Section 147Section 148Section 35DSection 36(1)(vii)

…hose to disallow those bad debts, in respect of which details were not available on record. In contrast, the sum of Rs.492.26 Crores has consciously been allowed by Ld. AO. Reliance has been placed on decision of Hon’ble Supreme Court rendered in TRF Limited [323 ITR 397] and Vijaya Bank [323 ITR 166] for the submissions that now there is no requirement to prove that the debts have actually become bad. 4.2.3 For assessee’s eligibility to claim deduction u/s 10(23G), our attention is drawn to the fact that stated issue stood squarely covered in assessee’s favor by the decision of this Tribunal rendered in assessee…

M/S. Assomac Machines Ltd., New Delhi vs. Addl. CIT, Ghaziabad

In the result appeal filed by assessee stands partly allowed

ITA 3599/DEL/2015[2010-11]Status: DisposedITAT Delhi03 Jun 2019AY 2010-11

Bench: Shri N.S. Saini & Smt. Beena A Pillaiay: 2010-11 Assomac Machines Ltd. Acit, Range 1 C/O M/S Rra Taxindia Ghaziabad D 28, South Extension Part I New Delhi 110 049 Vs.

For Appellant: Sh. Rakesh Gupta, AdvFor Respondent: Smt. Aastha Lakshmi, Sr.DR

Section 36(1)(vii)Section 40A(2)(b)Section 40A(3)Section 41(1)

…itted that assessee ITA No.3599/Del/2015 AY 2010-11 Assomac Machines Ltd. Vs. ACIT issued various communications and sent reminders to ddebtors for recovery. Placing reliance upon decision of Hon’ble Supreme Court in case of TRS Ltd vs CIT reported in (2010) 323 ITR 397, Ld.Counsel submitted that Ledger account of debtors placed at page 63 of paper book, gives details of debtors and outstanding payments due to assessee and further details along with invoices and reminders sent by assessee to these debtors has been placed at page 64-80 of paper book. 6.2. On the contrary Ld. DR placed reliance upon observations o…

The Dy. CIT, Circle -4, Ahmedabad vs. M/S. Gujarat State Financial Corporation, Gandhinagar

In the result, the appeal filed by the Revenue is dismissed

ITA 1494/AHD/2016[2011-12]Status: DisposedITAT Ahmedabad27 May 2019AY 2011-12

Bench: Shri Mahavir Prasad & Shri Waseem Ahmedआयकर अपील सं./Ita No.1494/Ahd/2016 "नधा"रण वष"/Asstt. Year: 2012-2013 D.C.I.T, M/S.Gujarat State Financial Circle-2(1)(1), Vs. Corporation, Ahmedabad. 1St Floor, Block No.10 Udhyog Bhavan, Gandhinagar.

For Appellant: Shri P.F Jain, A.R

Section 14A

…ts have actually been written off in the books of account of the assessee. The assessee has squared up the individual accounts to the debit of bad debts. In this view of the matter, and in the light of Hon'ble Supreme Court in the case of TRF Limited vs. CIT (323 ITR 397) which holds that a mere write off of the bad debts in the books of account, as irrecoverable, is sufficient to claim deductions as bad debts. Learned CIT(A) was, therefore, quite justified in granting relief to the assessee on this issue. As far provision of Rs.88,38,79,657/- is concerned, undoubtedly there is nothing on record to show, or even…

M/S. Adidas India Marketing Pvt. Ltd., New Delhi vs. ITO, New Delhi

In the result the Cross Objection filed by assessee stands partly allowed for statistical purposes

ITA 3727/DEL/2014[2006-07]Status: DisposedITAT Delhi27 May 2019AY 2006-07

Bench: Shri G.D.Agrawal & Smt. Beena A Pillaiay: 2006-07 Adidas India Marketing Pvt.Ltd. Vs. Ito, Co.Ward 1(2) Office No.6, 2Nd Floor, Sector B New Delhi Pocket No.7, Plot No.11 Vasant Kunj New Delhi 110 070 Pan: Aaaca5313P Ay: 2007-08 Ito, Co.Ward 1(2) Vs. Adidas India Marketing Pvt.Ltd. New Delhi Office No.6, 2Nd Floor, Sector B Pocket No.7, Plot No.11 Vasant Kunj New Delhi 110 070

For Appellant: Shri Ajay Vohra, Sr.AdvFor Respondent: Sh. Sanjay I Bara, CIT, D.R

Section 143(3)Section 143(3)(ii)Section 144CSection 92C

…sue of power of Assessing Officer to admit a claim which was not raised in the return of income and does not incline on the power of appellate authority. Instead placing reliance upon the decision of Hon’ble Supreme Court in case of TRF Ltd vs CIT reported in 323 ITR 397, Ld.Counsel submitted that it is not necessary for assessee to establish that the debt in fact had become irrecoverable and it was enough if bad debts is written off as irrecoverable in the accounts of assessee. 16. Ld.CIT, DR placed reliance upon the order of authorities below. 17. We have perused submissions advanced by both sides in the ligh…