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 367,154 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 147Section 14ASection 36(2)Section 148Section 40(a)(ia)Section 132

Issues it is cited on

section 36(2)section 36(1)(vii)business expediencysection 36(1)section 36commercial expediencyrevenue expendituredisallowance under section 14acapital expendituresection 28section 115jsection 14a

Judgments citing TRF Ltd. v. CIT

ACIT, Mumbai vs. Goenka Trading Co., Mumbai

In the result, all the three captioned appeals by the Revenue are dismissed

ITA 1425/MUM/2024[2015]Status: DisposedITAT Mumbai20 Jan 2025

Bench: Sunil Kumar Singh, Hon’Ble

For Appellant: Shri Fenil Bhatt, AdvFor Respondent: Shri Bhangepatil Pushkaraj Ramesh, Sr. DR

…| आयकर अपीलीय अिधकरण "ायपीठ, मुंबई | IN THE INCOME TAX APPELLATE TRIBUNAL “G” BENCH, MUMBAI SHRI NARENDRA KUMAR BILLAIYA, HON’BLE ACCOUNTANT MEMBER & BEFORE SUNIL KUMAR SINGH, HON’BLE JUDICIAL MEMBER I.T.A. No. 1425/Mum/2024 Assessment Year: 2015-16 & I.T.A. No. 1424/Mum/2024 Assessment Year: 2016-17 & I.T.A. No. 1524/Mum/2024 Assessment Year: 2017-18 ACIT-19(1), Goenka Trading, 506, 5th Floor Piramal Chamber Vs 11, Mehta Mahal, 15th Mathew Lalbaugh, Parel, Road Opera House, Mumbai - 400012 Mumbai - 400004. [PAN: AAAFG0225H] अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Assessee by : Shri Fenil Bhatt, Adv. Revenue…

ACIT, Mumbai vs. Goenka Trading Co., Mumbai

In the result, all the three captioned appeals by the Revenue are dismissed

ITA 1424/MUM/2024[2016]Status: DisposedITAT Mumbai20 Jan 2025

Bench: Sunil Kumar Singh, Hon’Ble

For Appellant: Shri Fenil Bhatt, AdvFor Respondent: Shri Bhangepatil Pushkaraj Ramesh, Sr. DR

…| आयकर अपीलीय अिधकरण "ायपीठ, मुंबई | IN THE INCOME TAX APPELLATE TRIBUNAL “G” BENCH, MUMBAI SHRI NARENDRA KUMAR BILLAIYA, HON’BLE ACCOUNTANT MEMBER & BEFORE SUNIL KUMAR SINGH, HON’BLE JUDICIAL MEMBER I.T.A. No. 1425/Mum/2024 Assessment Year: 2015-16 & I.T.A. No. 1424/Mum/2024 Assessment Year: 2016-17 & I.T.A. No. 1524/Mum/2024 Assessment Year: 2017-18 ACIT-19(1), Goenka Trading, 506, 5th Floor Piramal Chamber Vs 11, Mehta Mahal, 15th Mathew Lalbaugh, Parel, Road Opera House, Mumbai - 400012 Mumbai - 400004. [PAN: AAAFG0225H] अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Assessee by : Shri Fenil Bhatt, Adv. Revenue…

Shree Chandi Maa Mahakali Prachin Mandir Sidh Peeth Samiti, Sonipat vs. CPC, Banglore

ITA 4791/DEL/2024[2022-23]Status: DisposedITAT Delhi07 Jan 2025AY 2022-23

Bench: Shri Prakash Chand Yadav & Shri Brajesh Kumar Singh

For Appellant: Shri Ajay Vohra, Sr. A.RFor Respondent: Shri Bhopal Singh, Sr. D.R
Section 92C

…details of the parties to whom these debts pertain. 19. Ld. D.R. relied upon the orders of authorities below. Finding of the Bench: 20. After considering the rival submissions we observe that Hon'ble Supreme Court in the case of TRF Ltd. Vs. CIT reported in 323 ITR 397 has held that it is not necessary for an assessee to establish that the debt, in fact, has become irrecoverable. The Hon'ble Apex Court further held that if the assessee writes off these debts in its books of accounts as irrecoverable, then passing of these entries would be sufficient for allowing the claim of the assessee. We further observe tha…

Mehrunnisan Sherwani, Okhla vs. Income Tax Officer W 28(1), Delhi

In the result, appeal of the Revenue is dismissed and CO of the assessee is allowed

ITA 4728/DEL/2024[2012-2013]Status: DisposedITAT Delhi06 Jan 2025AY 2012-2013

Bench: Shri Vikas Awasthy & Shri S Rifaur Rahmanआअसं.1977/धिल्ली/2013(नि.व. 2009-10) Sahara India Commercial Corporation Ltd., Sahara India Sadan, 2A, Shakespeare Sarani, Kolkata 700071 ...... अपीलार्थी/Appellant Pan: Aadcs-6118-F बिाम Vs. Deputy Commissioner Of Income Tax, Central Circle-6, R. No. 334, E-2, Ara, ..... प्रनिवादी/Respondent Centre Jhandewalan Extn. New Delhi आअसं.4728, 2795, 4729, 4730 और 4731/धिल्ली/2017(नि.व. 2010-11 से 2014-15)

Section 142

…at the amounts written off had become unrecoverable. It is no more res integra that after amendment to section 36(1)(vii) of the Act, the assessee need not substantiate that the amounts are irrecoverable. The Hon’ble Apex Court in the case of TRF Ltd. vs CIT, 323 ITR 397 has held that it is sufficient that the assessee has written off the amounts in its books. Thus, in the light of settled legal position, we find no reason to interfere with the findings of the CIT(A) in deleting the disallowance. Hence, ground no. 5 of the Revenue’s appeal is dismissed. Deleting of Disallowance on Account of Proportionate Distri…

Patel Engineering Limited, Mumbai vs. DCIT CC-3(4), Mumbai

In the result, appeals of the Revenue are dismissed, except for one ground no

ITA 2801/MUM/2024[2017-18]Status: DisposedITAT Mumbai31 Dec 2024AY 2017-18

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

Section 194ASection 201

…IN THE INCOME TAX APPELLATE TRIBUNAL, ‘C’ BENCH MUMBAI BEFORE: SHRI AMIT SHUKLA, JUDICIAL MEMBER & SHRI GIRISH AGRAWAL, ACCOUNTANT MEMBER ITA No.3063/Mum/2024 (Assessment Year: 2017-18) & Assistant Vs. Patel Engineering Limited Commissioner of Patel Estate Off. S.V.Road Income Tax (TDS)2(1) Jogeshwari West / DCIT (CC) 3(4) Maharashtra-400 102 Mumbai PAN/GIR No.AAACP2567L (Appellant) .. (Respondent) ITA No.2802/Mum/2024 (Assessment Year :2018-19) Patel Engineering Limited Vs. Assistant Patel Estate Commissioner of Off. S.V.Road Income Tax Jogeshwari West (TDS)2(1) /DCIT Maharashtra-400102 (CC)-3(4) Mumbai PAN/GI…

The Dy CIT CC-38, Mumbai vs. M/S. United Phosphourous Ltd., Mumbai

ITA 4099/MUM/2004[2000-2001]Status: DisposedITAT Mumbai24 Dec 2024AY 2000-2001

Bench: Shri Amit Shukla & Smt.Renu Jauhri, Accountan Member

For Appellant: Ms. Vasanti Patel, Adv &For Respondent: Shri Heera Ram Choudhary, Sr. DR
Section 143(3)

…it being debited to Profit and Loss Account. It is well settled position that it is not necessary for the appellant to prove that the debt is irrecoverable. In this connection, reliance is placed on the decision of the Supreme Court in case of TRF Ltd vs. CIT 323 ITR 297 (SC). 14.10. Further, as per the provisions of section 36(1) (vii), bad debt written off is allowable as deduction provided that the bad debt or part thereof is taken into account in computing the income of the assessee. It is submitted that the interest in respect of the aforesaid inter-corporate deposit written off has been offered to tax in ea…

Astt. Commissioner of Income Tax, Lucknow vs. M/S Prag Industries (India) Pvt. Ltd., Lucknow

In the result, appeal of Revenue and Cross Objection of assessee, both are dismissed

ITA 660/LKW/2016[2013-14]Status: DisposedITAT Lucknow11 Dec 2024AY 2013-14

Bench: Shri Kul Bharat, Videshri Anadee Nath Misshra

Section 40A(2)

…aterials on record. We find that there is nothing on record to show that the aforesaid finding of facts recorded by the learned CIT(A) in the impugned appellate order are erroneous. Moreover, in view of order of Hon'ble Supreme Court in T.R.F. Limited vs. CIT 323 ITR 397/ 190 taxmann 391 (SC) and order of Hon'ble Delhi High Court in CIT vs. Samara India (P) Ltd. 216 taxman 93, it is well settled that for an assessee to claim deduction in relation to bad debt, it is not necessary to establish that the debt had become irrecoverable and further that it is sufficient if assessee forms such an opinion and writes off d…

Hybrid Financial Services Limited, Mumbai vs. ACIT 10(1)(1), Aaykar Bhavan Mumbai

In the result, appeal of the assessee is allowed

ITA 3093/MUM/2024[2014-15]Status: DisposedITAT Mumbai11 Dec 2024AY 2014-15

Bench: Shri Narender Kumar Choudhry & Shri Girish Agrawalassessment Year: 2014-15

For Appellant: Shri K. Chandramouli, CAFor Respondent: Shri P.D. Chougule, Sr. DR
Section 143(3)

…bad debts written off during the year amounting to Rs.6.17,28,003/- as irrecoverable and claimed as deduction in the revised computation were sought to be allowed. 3.9. Assessee relied upon the decision of Hon’ble Supreme Court in the case of TRF Ltd [2010] 323 ITR 397 (SC) wherein it is held that after 01.04.1989, for allowing deduction for the amount of any bad debts or part thereof u/s 36(1)(vii) of the Act, it is not necessary for assessee to establish that the debt in fact has become irrecoverable; it is enough if that debt is written off as irrecoverable in the books of accounts of assessee. Assessee also…

The Dy. Commissioner of Income Tax, Circle-1(1)(1), Vadodara vs. Ambalal Sarabhi Enterprises Limited, Vadodara

ITA 2067/AHD/2016[2007-08]Status: DisposedITAT Ahmedabad03 Dec 2024AY 2007-08

Bench: Ms. Suchitra Kamble & Shri Makarand V. Mahadeokarआयकर अपील सं/ िनधा"रण वष"/ Sl. Appeal(S) By :

For Appellant: Shri Bandish Soparkar, A.R. &For Respondent: Shri R.N. Dsouza, CIT-DR &
Section 143(3)Section 14ASection 40Section 40A(3)Section 40A(7)Section 43B

…terprises Ltd. vs. ACIT-DCIT (by Assessee and Revenue) Asst. Years : 2002-03 to 2007-08 59 books of accounts. The necessity to establish that the debt has become bad is no longer applicable. The Hon’ble Supreme Court in the case of T.R.F. Ltd. v. CIT [2010] 323 ITR 397 (SC) clarified that the write-off suffices to claim the deduction. The assessee demonstrated that the debts were written off in the books of accounts, fulfilling the primary condition under Section 36(1)(vii). Additionally, the condition under Section 36(2) of the Act, requiring that the debts be included as income in earlier years, is satisfied…

The Dy. Commissioner of Income Tax, Circle-1(1)(1), Vadodara vs. Ambalal Sarabhi Enterprises Limited, Vadodara

ITA 2066/AHD/2016[2005-06]Status: DisposedITAT Ahmedabad03 Dec 2024AY 2005-06

Bench: Ms. Suchitra Kamble & Shri Makarand V. Mahadeokarआयकर अपील सं/ िनधा"रण वष"/ Sl. Appeal(S) By :

For Appellant: Shri Bandish Soparkar, A.R. &For Respondent: Shri R.N. Dsouza, CIT-DR &
Section 143(3)Section 14ASection 40Section 40A(3)Section 40A(7)Section 43B

…terprises Ltd. vs. ACIT-DCIT (by Assessee and Revenue) Asst. Years : 2002-03 to 2007-08 59 books of accounts. The necessity to establish that the debt has become bad is no longer applicable. The Hon’ble Supreme Court in the case of T.R.F. Ltd. v. CIT [2010] 323 ITR 397 (SC) clarified that the write-off suffices to claim the deduction. The assessee demonstrated that the debts were written off in the books of accounts, fulfilling the primary condition under Section 36(1)(vii). Additionally, the condition under Section 36(2) of the Act, requiring that the debts be included as income in earlier years, is satisfied…

Ambalal Sarabhai Enterprises Ltd., Baroda vs. The Dy. Commissioner of Income Tax, Circle-1(1)(1), Baroda

ITA 1783/AHD/2016[2007-08]Status: DisposedITAT Ahmedabad03 Dec 2024AY 2007-08

Bench: Ms. Suchitra Kamble & Shri Makarand V. Mahadeokarआयकर अपील सं/ िनधा"रण वष"/ Sl. Appeal(S) By :

For Appellant: Shri Bandish Soparkar, A.R. &For Respondent: Shri R.N. Dsouza, CIT-DR &
Section 143(3)Section 14ASection 40Section 40A(3)Section 40A(7)Section 43B

…terprises Ltd. vs. ACIT-DCIT (by Assessee and Revenue) Asst. Years : 2002-03 to 2007-08 59 books of accounts. The necessity to establish that the debt has become bad is no longer applicable. The Hon’ble Supreme Court in the case of T.R.F. Ltd. v. CIT [2010] 323 ITR 397 (SC) clarified that the write-off suffices to claim the deduction. The assessee demonstrated that the debts were written off in the books of accounts, fulfilling the primary condition under Section 36(1)(vii). Additionally, the condition under Section 36(2) of the Act, requiring that the debts be included as income in earlier years, is satisfied…

Ambalal Sarabhai Enterprises Ltd., Baroda vs. The Dy.Commissioner of Income Tax, Circle-1(1)(1), Baroda

ITA 1782/AHD/2016[2005-06]Status: DisposedITAT Ahmedabad03 Dec 2024AY 2005-06

Bench: Ms. Suchitra Kamble & Shri Makarand V. Mahadeokarआयकर अपील सं/ िनधा"रण वष"/ Sl. Appeal(S) By :

For Appellant: Shri Bandish Soparkar, A.R. &For Respondent: Shri R.N. Dsouza, CIT-DR &
Section 143(3)Section 14ASection 40Section 40A(3)Section 40A(7)Section 43B

…terprises Ltd. vs. ACIT-DCIT (by Assessee and Revenue) Asst. Years : 2002-03 to 2007-08 59 books of accounts. The necessity to establish that the debt has become bad is no longer applicable. The Hon’ble Supreme Court in the case of T.R.F. Ltd. v. CIT [2010] 323 ITR 397 (SC) clarified that the write-off suffices to claim the deduction. The assessee demonstrated that the debts were written off in the books of accounts, fulfilling the primary condition under Section 36(1)(vii). Additionally, the condition under Section 36(2) of the Act, requiring that the debts be included as income in earlier years, is satisfied…

The Dy.Commissioner of Income Tax, Circle-1(1)(1), Vadodara vs. Ambalal Sarabhai Enterprises Limited, Vadodara

ITA 1594/AHD/2016[2004-05]Status: DisposedITAT Ahmedabad03 Dec 2024AY 2004-05

Bench: Ms. Suchitra Kamble & Shri Makarand V. Mahadeokarआयकर अपील सं/ िनधा"रण वष"/ Sl. Appeal(S) By :

For Appellant: Shri Bandish Soparkar, A.R. &For Respondent: Shri R.N. Dsouza, CIT-DR &
Section 143(3)Section 14ASection 40Section 40A(3)Section 40A(7)Section 43B

…terprises Ltd. vs. ACIT-DCIT (by Assessee and Revenue) Asst. Years : 2002-03 to 2007-08 59 books of accounts. The necessity to establish that the debt has become bad is no longer applicable. The Hon’ble Supreme Court in the case of T.R.F. Ltd. v. CIT [2010] 323 ITR 397 (SC) clarified that the write-off suffices to claim the deduction. The assessee demonstrated that the debts were written off in the books of accounts, fulfilling the primary condition under Section 36(1)(vii). Additionally, the condition under Section 36(2) of the Act, requiring that the debts be included as income in earlier years, is satisfied…

Ambalal Sarabhai Enterprises Ltd., Baroda vs. The Dy. Commissioner of Income Tax-1(1)(1), Baroda

ITA 1291/AHD/2016[2006-07]Status: DisposedITAT Ahmedabad03 Dec 2024AY 2006-07

Bench: Ms. Suchitra Kamble & Shri Makarand V. Mahadeokarआयकर अपील सं/ िनधा"रण वष"/ Sl. Appeal(S) By :

For Appellant: Shri Bandish Soparkar, A.R. &For Respondent: Shri R.N. Dsouza, CIT-DR &
Section 143(3)Section 14ASection 40Section 40A(3)Section 40A(7)Section 43B

…terprises Ltd. vs. ACIT-DCIT (by Assessee and Revenue) Asst. Years : 2002-03 to 2007-08 59 books of accounts. The necessity to establish that the debt has become bad is no longer applicable. The Hon’ble Supreme Court in the case of T.R.F. Ltd. v. CIT [2010] 323 ITR 397 (SC) clarified that the write-off suffices to claim the deduction. The assessee demonstrated that the debts were written off in the books of accounts, fulfilling the primary condition under Section 36(1)(vii). Additionally, the condition under Section 36(2) of the Act, requiring that the debts be included as income in earlier years, is satisfied…

Ambalal Sarabhai Enterprises Ltd., Baroda vs. The Dy. Commissioner of Income Tax-1(1)(1), Baroda

ITA 1290/AHD/2016[2004-05]Status: DisposedITAT Ahmedabad03 Dec 2024AY 2004-05

Bench: Ms. Suchitra Kamble & Shri Makarand V. Mahadeokarआयकर अपील सं/ िनधा"रण वष"/ Sl. Appeal(S) By :

For Appellant: Shri Bandish Soparkar, A.R. &For Respondent: Shri R.N. Dsouza, CIT-DR &
Section 143(3)Section 14ASection 40Section 40A(3)Section 40A(7)Section 43B

…terprises Ltd. vs. ACIT-DCIT (by Assessee and Revenue) Asst. Years : 2002-03 to 2007-08 59 books of accounts. The necessity to establish that the debt has become bad is no longer applicable. The Hon’ble Supreme Court in the case of T.R.F. Ltd. v. CIT [2010] 323 ITR 397 (SC) clarified that the write-off suffices to claim the deduction. The assessee demonstrated that the debts were written off in the books of accounts, fulfilling the primary condition under Section 36(1)(vii). Additionally, the condition under Section 36(2) of the Act, requiring that the debts be included as income in earlier years, is satisfied…

Ambalal Sarabhai Enterprises Limited, Baroda vs. The ACIT., Circle-1(1), Baroda

ITA 1773/AHD/2015[2003-04]Status: DisposedITAT Ahmedabad03 Dec 2024AY 2003-04

Bench: Ms. Suchitra Kamble & Shri Makarand V. Mahadeokarआयकर अपील सं/ िनधा"रण वष"/ Sl. Appeal(S) By :

For Appellant: Shri Bandish Soparkar, A.R. &For Respondent: Shri R.N. Dsouza, CIT-DR &
Section 143(3)Section 14ASection 40Section 40A(3)Section 40A(7)Section 43B

…terprises Ltd. vs. ACIT-DCIT (by Assessee and Revenue) Asst. Years : 2002-03 to 2007-08 59 books of accounts. The necessity to establish that the debt has become bad is no longer applicable. The Hon’ble Supreme Court in the case of T.R.F. Ltd. v. CIT [2010] 323 ITR 397 (SC) clarified that the write-off suffices to claim the deduction. The assessee demonstrated that the debts were written off in the books of accounts, fulfilling the primary condition under Section 36(1)(vii). Additionally, the condition under Section 36(2) of the Act, requiring that the debts be included as income in earlier years, is satisfied…

Ambalal Sarabhai Enterprises Limited, Baroda vs. The ACIT., Circle-1(1), Baroda

ITA 1772/AHD/2015[2002-03]Status: DisposedITAT Ahmedabad03 Dec 2024AY 2002-03

Bench: Ms. Suchitra Kamble & Shri Makarand V. Mahadeokarआयकर अपील सं/ िनधा"रण वष"/ Sl. Appeal(S) By :

For Appellant: Shri Bandish Soparkar, A.R. &For Respondent: Shri R.N. Dsouza, CIT-DR &
Section 143(3)Section 14ASection 40Section 40A(3)Section 40A(7)Section 43B

…terprises Ltd. vs. ACIT-DCIT (by Assessee and Revenue) Asst. Years : 2002-03 to 2007-08 59 books of accounts. The necessity to establish that the debt has become bad is no longer applicable. The Hon’ble Supreme Court in the case of T.R.F. Ltd. v. CIT [2010] 323 ITR 397 (SC) clarified that the write-off suffices to claim the deduction. The assessee demonstrated that the debts were written off in the books of accounts, fulfilling the primary condition under Section 36(1)(vii). Additionally, the condition under Section 36(2) of the Act, requiring that the debts be included as income in earlier years, is satisfied…

ACIT 32 1, Mumbai vs. Vidhi Enterprises, Mumbai

In the result, the appeal of the assessee is partly allowed for In the result, the appeal of the assessee is partly allowed for statistical purposes whereas appeal of the Revenue is dismissed

ITA 2151/MUM/2024[2015 16]Status: DisposedITAT Mumbai28 Nov 2024

Bench: Shri Om Prakash Kant () Before Shri Om Prakash Kant () Before Shri Om Prakash Kant () & Shri Sandeep Singh Karhail () Shri Sandeep Singh Karhail () Shri Sandeep Singh Karhail ()

For Appellant: Mr. Snehal Shah
Section 147

…allowed. In this regard, appellant quoted the relevant provision of the section. In this regard reliance is placed on the H In this regard reliance is placed on the Hon'ble Supreme Court in the case on'ble Supreme Court in the case of TRF Ltd. vs. CIT (2010) 323 ITR 397 (SC), which states that bad debt of TRF Ltd. vs. CIT (2010) 323 ITR 397 (SC), which states that bad debt of TRF Ltd. vs. CIT (2010) 323 ITR 397 (SC), which states that bad debt can be written off, only if the assessee had offered income to the extent of can be written off, only if the assessee had offered income to the extent of can be written of…

Vidhi Enterprises, Mumbai vs. Deputy Commissioner of Income Tax, Mumbai

In the result, the appeal of the assessee is partly allowed for In the result, the appeal of the assessee is partly allowed for statistical purposes whereas appeal of the Revenue is dismissed

ITA 2060/MUM/2024[A.Y 2015-1]Status: DisposedITAT Mumbai28 Nov 2024

Bench: Shri Om Prakash Kant () Before Shri Om Prakash Kant () Before Shri Om Prakash Kant () & Shri Sandeep Singh Karhail () Shri Sandeep Singh Karhail () Shri Sandeep Singh Karhail ()

For Appellant: Mr. Snehal Shah
Section 147

…allowed. In this regard, appellant quoted the relevant provision of the section. In this regard reliance is placed on the H In this regard reliance is placed on the Hon'ble Supreme Court in the case on'ble Supreme Court in the case of TRF Ltd. vs. CIT (2010) 323 ITR 397 (SC), which states that bad debt of TRF Ltd. vs. CIT (2010) 323 ITR 397 (SC), which states that bad debt of TRF Ltd. vs. CIT (2010) 323 ITR 397 (SC), which states that bad debt can be written off, only if the assessee had offered income to the extent of can be written off, only if the assessee had offered income to the extent of can be written of…

Nuevosol Energy Private Limited, Hyderabad vs. ACIT., Circle-16(1), Hyderabad

In the result, appeal filed by the assessee is allowed

ITA 958/HYD/2024[2018-19]Status: DisposedITAT Hyderabad27 Nov 2024AY 2018-19

Bench: Shri Manjunatha G. & Shri K. Narasimha Charyआ.अपी.सं /Ita No.958/Hyd/2024 (निर्धारण वर्ा/Assessment Year: 2018-19) Nuevosol Energy Private Vs. Assistant Commissioner Limited Of Income Tax Hyderabad Circle-16(1) [Pan : Aadcn7551K] Hyderabad (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Shri Gvn Hari, Ar रधजस् व द्वधरध/Revenue By:: Shri Srinath Sadanala, Dr सुिवधई की तधरीख/Date Of Hearing: 26/11/2024 घोर्णध की तधरीख/Date Of 27/11/2024 Pronouncement: आदेश / Order Per. Manjunatha G., A.M: This Appeal Filed By The Assessee Is Directed Against The Order Dated 25/07/2024 Of The Learned Commissioner Of Income Tax (Appeals) [Learned Cit(A)], National Faceless Appeal Centre (Nfac), Delhi, Relating To A.Y.2018-19 On The Following Grounds : 1. The Order Of The Learned Commissioner Of Income Tax (Appeals) Is Contrary To The Facts & Also The Law Applicable To The Facts Of The Case. 2. The Learned Commissioner Of Income Tax (Appeals) Is Not Justified In Sustaining The Addition Of Rs.2,65,80,027

For Appellant: Shri GVN Hari, ARFor Respondent: : Shri Srinath Sadanala, DR
Section 36(1)(vii)

…led all evidences to prove that the amounts claimed towards write off of bad debts is actually written off in the books of accounts of the assessee. In 4 this regard, the assessee relied on the decision of Hon'ble Supreme Court in the case of TRF Ltd. Vs. CIT 323 ITR 397(SC). 4. The Ld.CIT(A) after considering the relevant submissions of the assessee and also taking note of reasons given by the Assessing Officer to make additions towards write off of bad debts, observed that the appellant is not able to prove the claim of bad debts with relevant evidences and also how the deduction claimed towards write off of b…