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“Section 36(2)”

Section References (mined)Section 36Section 36(2)440 judgments

The decision most relied on for Section 36(2) is CIT v. Reliance Utilities & Power Ltd. (313 ITR 340), cited in 2,118 judgments on BharatTax.

Leading authorities on Section 36(2)

CIT v. Reliance Utilities & Power Ltd.
313 ITR 340 · 2009 · High Court
2,118
citing judgments

Where an assessee claims that investments were made out of own funds, interest disallowance under Section 14A read with Rule 8D may not apply if the assessee demonstrates the availability of sufficient interest-free funds to cover such investments.

CIT v. AIMIL Ltd.
321 ITR 508 · 2010 · High Court
1,629
citing judgments

Employee contributions to PF and ESIC, deposited beyond the due date under the respective Acts but within the due date for filing the income tax return under Section 139(1), are allowable deductions under Section 36(1)(va). Such disallowance cannot be made during processing under Section 143(1).

Checkmate Services Pvt. Ltd. v. CIT
143 Taxmann.com 178 · 2022 · Supreme Court
1,392
citing judgments

Employee contributions to provident fund and ESI deposited by an employer beyond the due dates prescribed under the respective special Acts are not allowable as a deduction under section 36(1)(va) of the Income-tax Act, 1961. Such disallowance can be made during processing under section 143(1).

CIT v. Alom Extrusions Ltd.
319 ITR 306 · 2009 · Supreme Court
1,344
citing judgments

A proviso inserted into a section to remedy unintended consequences, make the section workable, or supply an obvious omission must be read retrospectively in operation to give effect to the section as a whole.

CIT v. Gujarat State Road Transport Corporation
366 ITR 170 · 2014 · High Court
1,158
citing judgments

Employees' contributions to welfare funds, such as provident fund, are not allowable as a deduction under section 36(1)(va) if deposited beyond the due date prescribed under the respective welfare statutes, even by a single day. Such delayed deposits are not cured even if made before the income-tax return filing due date.

TRF Ltd. v. CIT
323 ITR 397 · 2010 · Supreme Court
714
citing judgments

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.

279 ITR 331/149 Taxman 15 (Guj.); 5. CIT v. Sabari Enterprises
298 ITR 141 · 2008 · High Court
706
citing judgments

Employee contributions to provident fund or ESI, even if deposited after the due date specified in the respective welfare statutes, are allowable as a deduction under Section 36(1)(va) if paid before the due date for filing the income-tax return. This judgment aligns the treatment of employee contributions with employer contributions under Section 43B.

(i) CIT v. Merchem Ltd.
378 ITR 443 · 2015 · High Court
631
citing judgments

Belated remittance of employees' contribution to ESI and PF, even if deposited before the due date for filing the return of income under Section 139(1), is not allowed as a deduction. This disallowance falls under Section 36(1)(va) read with Section 2(24)(x), as Section 43B applies only to employer's contributions.

Judgments citing Section 36(2)

Smt Rashmi Ramesh Damani, Mumbai vs. DCIT, Circle 17(1), Mumbai

ITA 1129/MUM/2025[2014-15]Status: DisposedITAT Mumbai02 Jan 2026AY 2014-15

Bench: SHRI RAHUL CHAUDHARY, JUDICIAL MEMBER SHRI PRABHASH SHANKAR (Accountant Member)

For Appellant: Shri M. P. LohiaFor Respondent: Shri Vikas Chandra
Section 143(3)Section 271(1)(c)

Taxes New Delhi , Dated 30th May, 2016 Subject: – Admissibility of claim of deduction of Bad Debt under section 36(1) (vii) read with section 36(2) of the Income-Tax Act , 1961— reg. 10 Assessment Year 2014-2015 Proposals have been received by the Central Board of Direct Taxes regarding ... books of accounts of the assessee for that previous year and it fulfills the conditions stipulated in sub section (2) of sub- section 36(2) of the Act. 5. Accordingly, no appeals may henceforth be filed on this ground and appeals already filed, if any, on this issue before various

Dy. Commissioner of Income Tax, Circle-16(1), C.R Building, ITO New Delhi vs. M M Healthcare Ltd., Pushpanjali, East Delhi, Anand Vihar, Delhi

ITA 3522/DEL/2025[2022-23]Status: DisposedITAT Delhi17 Dec 2025AY 2022-23

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwalassessment Year: 2022-23 Dy. Commissioner Of Vs. M/S. M. M. Healthcare Ltd., Income Tax, Circle-16(1), Pushpanjali, East Delhi, New Delhi Anand Vihar, New Delhi Pan: Aaacm1799D (Appellant) (Respondent) With C.O. No.238/Del/2025 [Arising Out Of Ita No.3522/Del/2025] Assessment Year: 2022-23 M/S. M. M. Healthcare Ltd., Vs. Dy. Commissioner Of Income Pushpanjali, East Delhi, Tax, Circle-16(1), Anand Vihar, New Delhi New Delhi Pan: Aaacm1799D (Appellant) (Respondent) Assessee By Sh. Ruchesh Sinha, Adv. Ms. Monalisa Maity, Adv. Department By Ms. Ankush Kalra, Sr. Dr Date Of Hearing 03.12.2025 Date Of Pronouncement 17.12.2025 Order Per Satbeer Singh Godara, Jm This Revenue’S Appeal Ita No.3522/Del/2025 Along With The Assessee’S Cross Objection C.O. No.238/Del/2025 For Assessment

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

which is subject to provisions of sub section 2 of section 36 of IT Act. The provisions of section 36(2) are as under: “[ no such deduction shall be allowed unless such debt or part thereof has been taken into account in computing the income of the assessee

M. Sons Gems N Jewellery Pvt. Ltd., New Delhi vs. ACIT, Central Circle-20, New Delhi

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

ITA 4549/DEL/2019[2015-16]Status: DisposedITAT Delhi17 Dec 2025AY 2015-16

Bench: Shri Anubhav Sharma& Shri Amitabh Shukla[Assessment Year: 2015-16] M. Sons Gems N Jewellery Acit Pvt. Ltd. 4852/24, First Floor, Central Circle – 20 Near Sanjivan Hospital Vs New Delhi Ansari Road, Daryaganj, New Delhi Pan-Aadcm9406A Appellant Respondent Assessee By None Revenue By Ms. Monika Singh, Cit Dr Date Of Hearing 28.10.2025 Date Of Pronouncement 17.12.2025

Section 143(2)Section 143(3)Section 153CSection 251Section 36(1)Section 36(1)(vii)Section 43B

assessee is entitled u/s 36(1)(vii) of the Act to claim an amount as bad debts subject to satisfaction of condition in section 36(2). The assessee has placed on records through its paper book to adduce that the amount of receipts have been offered qua sale proceeds made

Asst. Commissioner of Income Tax Central Circle 2(3) Mumbai, Mumbai vs. Indusind Media and Communication Ltd, Mumbai

ITA 3945/MUM/2025[2020-21]Status: DisposedITAT Mumbai16 Dec 2025AY 2020-21

Bench: Ms. Suchitra Raghunath Kamble & Shri Girish Agrawal

Section 143(3)Section 195Section 36(1)(vii)Section 36(2)Section 40Section 9(1)(vi)

identity of the debtors, which are essential to establish the genuineness of the debt and compliance with the conditions laid down under section 36(2) of the Act?" 2. Whether on the facts and in the circumstances of the case and in law, the Ld. CIT(A) erred in holding ... section 36(1)(vii) of the Act which allows deduction for bad debts written off in the books, subject to compliance with section 36(2). 5. 3. Assessee submitted that the decision to treat a debt as "bad" is a commercial decision of the assessee, based on material available

Elcome Technologies Private Limited, Mumbai vs. Dy. Commissioner of Income Tax, Mumbai

Appeal of the assessee is partly allowed

ITA 6188/MUM/2025[2018-19]Status: DisposedITAT Mumbai09 Dec 2025AY 2018-19

Bench: Shri Saktijit Dey, Vp & Ms Padmavathy S, Am

For Respondent: Shri Himanshu Joshi, Sr.-DR
Section 250Section 250(4)Section 37Section 41(1)

that the debt which was claimed as deduction had become bad during the previous year and Assessing Officer was empowered in terms of Section 36(2) to allow the deduction in another year, if he was of the view that the debt had become in an earlier or later year ... assessee is obliged to prove to the AO that the case satisfies the ingredients of Section 36(1)(vii) as well as Section 36(2) of the Act." 29.& 30. ************* 31. The legislature by amendment has sought to exclude the burden on the assessee to prove that the debt

Gbt India Private Limited, New Delhi vs. ACIT, OSD, Delhi

In the result, the assessee’s appeal is allowed as above

ITA 1764/DEL/2022[2018-19]Status: DisposedITAT Delhi26 Nov 2025AY 2018-19

Bench: Shri Challa Nagendra Prasad & Shri Avdhesh Kumar Mishra

Section 143(3)Section 234ASection 36(1)(vii)Section 36(2)

despite the fact that the twin conditions for allowance of deduction of bad debts contained in Section 36(1)(vii) read with Section 36(2) of the Act are satisfied 8. That, on the facts and circumstances of the case and in law, the Hon'ble DRP/Ld. AO erred

Asst.Commissioner of Income Tax(It)-2(1)-2, Mumbai vs. Dbs Bank Limited, Mumbai

In the result, appeal of the assessee is allowed

ITA 2430/MUM/2025[2017-18]Status: DisposedITAT Mumbai18 Nov 2025AY 2017-18

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI PRABHASH SHANKAR (Accountant Member)

Section 143(3)Section 28Section 36(1)(vii)Section 37(1)

written off in the accounts as irrecoverable. The statutory requirement for allowance of bad debt under section 36(1)(vii) read with section 36(2) thus stands fulfilled. The character of the loss is not altered merely because the erosion becomes evident on the date on which shares are credited

Asst. Commissioner of Income Tax, Mumbai vs. Dbs Bank Limited, Mumbai

In the result, appeal of the assessee is allowed

ITA 2429/MUM/2025[2016-17]Status: DisposedITAT Mumbai18 Nov 2025AY 2016-17

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI PRABHASH SHANKAR (Accountant Member)

Section 143(3)Section 28Section 36(1)(vii)Section 37(1)

written off in the accounts as irrecoverable. The statutory requirement for allowance of bad debt under section 36(1)(vii) read with section 36(2) thus stands fulfilled. The character of the loss is not altered merely because the erosion becomes evident on the date on which shares are credited

ACIT, Circle-1(1), New Delhi, C.R. Building vs. Aircom International India Pvt Ltd, Delhi

The appeal of the Revenue is dismissed

ITA 3096/DEL/2023[2014-15]Status: DisposedITAT Delhi14 Nov 2025AY 2014-15

Bench: Shri S. Rifaur Rahman & Shri Anubhav Sharmaassessment Year : 2014-15 Dcit, Vs. M/S Aircom International India Pvt. Ltd., Circle-1(1), M-12, Balrama House, New Delhi. Karampura Complex, Opp. Milan Cinema, Karam Pura West Delhi Delhi – 110 015. Pan: Aadca0915A (Appellant) (Respondent) Assessee By : Shri Salil Kapoor, Advocate; Ms Ananya Kapoor, Advocate; & Shri Shivam Yadav, Advocate. Revenue By : Shri Ajay Kumar Arora, Sr. Dr Date Of Hearing : 06.11.2025 Date Of Pronouncement : 14.11.2025 Order

For Appellant: Shri Salil Kapoor, AdvocateFor Respondent: Shri Ajay Kumar Arora, Sr. DR
Section 143(3)Section 250(4)Section 36(1)(vii)Section 36(2)Section 37(1)

follows; “Ground no 3 is against Disallowance of Bad Debts amounting to Rs.1,26,71,902 under section 36(1)(vii) read with section 36(2) of the Act. During the assessment proceedings it was seen that the assessee has claimed trade receivables written off under the head 'Other Expenses

Erevmax Technologies Pvt. Ltd., Kolkata vs. D.C.I.T./A.C.I.T., Tp-1, Kolkata

Appeal of the assessee is partly allowed for statistical purposes

ITA 2551/KOL/2024[2021-2022]Status: DisposedITAT Kolkata27 Oct 2025AY 2021-2022

Bench: Us In The Paper Book)

Section 143(3)

IN THE INCOME TAX APPELLATE TRIBUNAL “C” BENCH, KOLKATA SHRI GEORGE MATHAN, JUDICIAL MEMBER SHRI SANJAY AWASTHI, ACCOUNTANT MEMBER I.T.A

Dy. Commissioner of Income Tax Circle - 3(3)(1), Mumbai vs. Small Industries Development Bank of India, Mumbai

ITA 3173/MUM/2023[2018-19]Status: DisposedITAT Mumbai10 Oct 2025AY 2018-19

Bench: Justice (Retd.) C V Bhadang & Ms Padmavathy S, Am

Section 115JSection 14ASection 250Section 36(1)Section 36(1)(vii)Section 36(1)(viia)Section 36(1)(viii)

IN THE INCOME TAX APPELLATE TRIBUNAL “G” BENCH, MUMBAI BEFORE JUSTICE (RETD.) C V BHADANG, PRESIDENT & MS PADMAVATHY S, AM

Dy. Commissioner of Income Tax Circle - 3(3)(1), Mumbai vs. Small Industries Development Bank of India, Mumbai

ITA 3160/MUM/2023[2017-18]Status: DisposedITAT Mumbai10 Oct 2025AY 2017-18

Bench: Justice (Retd.) C V Bhadang & Ms Padmavathy S, Am

For Respondent: Shri Arun Kanti Datta, CIT-DR
Section 115JSection 14ASection 250Section 36(1)Section 36(1)(vii)Section 36(1)(viia)

IN THE INCOME TAX APPELLATE TRIBUNAL “G” BENCH, MUMBAI BEFORE JUSTICE (RETD.) C V BHADANG, PRESIDENT & MS PADMAVATHY S, AM

Small Industries Development Bank of India, Mumbai vs. Deputy Commissioner of Income Tax Circle 3(3)(1), Mumbai

ITA 2971/MUM/2023[2017-18]Status: DisposedITAT Mumbai10 Oct 2025AY 2017-18

Bench: Justice (Retd.) C V Bhadang & Ms Padmavathy S, Am

For Appellant: Shri Arun Kanti Datta, CIT-DRFor Respondent: Assessee by
Section 115JSection 14ASection 250Section 36(1)Section 36(1)(vii)Section 36(1)(viia)Section 36(1)(viii)

IN THE INCOME TAX APPELLATE TRIBUNAL “G” BENCH, MUMBAI BEFORE JUSTICE (RETD.) C V BHADANG, PRESIDENT & MS PADMAVATHY S, AM

Small Industries Development Bank of India, Mumbai vs. Deputy Commissioner of Income Tax Circle 3(3)(1), Mumbai

ITA 2970/MUM/2023[2018-19]Status: DisposedITAT Mumbai10 Oct 2025AY 2018-19

Bench: Justice (Retd.) C V Bhadang & Ms Padmavathy S, Am

For Respondent: Shri Arun Kanti Datta, CIT-DR
Section 115JSection 14ASection 250Section 36(1)Section 36(1)(vii)Section 36(1)(viia)

IN THE INCOME TAX APPELLATE TRIBUNAL “G” BENCH, MUMBAI BEFORE JUSTICE (RETD.) C V BHADANG, PRESIDENT & MS PADMAVATHY S, AM

Dy. Commissioner of Income Tax Circle - 3(3)(1), Mumbai vs. Small Industries Development Bank of India, Mumbai

ITA 2943/MUM/2023[2014-15]Status: DisposedITAT Mumbai10 Oct 2025AY 2014-15

Bench: Justice (Retd.) C V Bhadang & Ms Padmavathy S, Am

For Respondent: Shri Arun Kanti Datta, CIT-DR
Section 115JSection 14ASection 250Section 36(1)Section 36(1)(vii)Section 36(1)(viia)

IN THE INCOME TAX APPELLATE TRIBUNAL “G” BENCH, MUMBAI BEFORE JUSTICE (RETD.) C V BHADANG, PRESIDENT & MS PADMAVATHY S, AM

Dy. Commissioner of Income Tax Circle - 3(3)(1), Mumbai vs. Small Industries Development Bank of India, Mumbai

ITA 2894/MUM/2023[2015-16]Status: DisposedITAT Mumbai10 Oct 2025AY 2015-16

Bench: Justice (Retd.) C V Bhadang & Ms Padmavathy S, Am

For Respondent: Shri Arun Kanti Datta, CIT-DR
Section 115JSection 14ASection 250Section 36(1)Section 36(1)(vii)Section 36(1)(viia)

IN THE INCOME TAX APPELLATE TRIBUNAL “G” BENCH, MUMBAI BEFORE JUSTICE (RETD.) C V BHADANG, PRESIDENT & MS PADMAVATHY S, AM

Dy. Commissioner of Income Tax Circle - 3(3)(1), Mumbai vs. Small Industries Development Bank of India, Mumbai

ITA 2893/MUM/2023[2016-17]Status: DisposedITAT Mumbai10 Oct 2025AY 2016-17

Bench: Justice (Retd.) C V Bhadang & Ms Padmavathy S, Am

For Appellant: Shri Arun Kanti Datta, CIT-DR
Section 115JSection 14ASection 250Section 36(1)Section 36(1)(vii)Section 36(1)(viia)Section 36(1)(viii)

IN THE INCOME TAX APPELLATE TRIBUNAL “G” BENCH, MUMBAI BEFORE JUSTICE (RETD.) C V BHADANG, PRESIDENT & MS PADMAVATHY S, AM

DCIT-15.1.2, Mumbai, Aayakar Bhavan vs. Ispat Infrastructure India Ltd, Mumbai

In the result, the appeal by the Revenue is allowed for statistical purposes

ITA 1502/MUM/2025[2015]Status: DisposedITAT Mumbai26 Sept 2025

Bench: Shri Narendra Kumar Billaiyashri Sandeep Singh Karhaildeputy Commissioner Of Income Tax – 15(1)(2), Aayakar Bhawan, Churchgate, ............... Appellant Mumbai - 400020 V/S Ispat Infrastructure India Ltd., Office No.470 Central Facility Building, ……………… Respondent Phase – Ii, Sector 19 Vashi, Navi Mumbai - 400705 Pan : Aabci0639P Assessee By : Shri Hemant Vora Revenue By : Shri A.M.K. Mahadevan, Sr.Dr

For Appellant: Shri Hemant VoraFor Respondent: Shri A.M.K. Mahadevan, Sr.DR
Section 142(1)Section 143(2)Section 143(3)Section 250Section 36(1)(vii)Section 36(2)

learned Departmental Representative (“learned DR”) submitted that the learned CIT(A) has not examined whether the assessee has complied with the conditions of section 36(2) of the Act and how the income was offered in the earlier year. 7. On the other hand, the learned Authorised Representative (“learned ... Taxman 391 (SC). However, at the same time, it is necessary that the assessee satisfies the conditions of the provisions of section 36(2) of the Act. However, in the present case, we do not find that the same has been examined by the learned CIT(A). Furthermore

ACIT, Cir 8(2)(1), Mumbai vs. Western India Garments Pvt. Ltd., Mumbai

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

ITA 4211/MUM/2023[2014-15]Status: DisposedITAT Mumbai22 Sept 2025AY 2014-15

Bench: Smt. Beena Pillai & Shri Girish Agrawalassessment Year: 2014-15 Pico Capital Private Limited Deputy Commissioner Of (Successor In Interest Of M/S Income Tax-8(3)(2), Western India Garments Private Mumbai Limited ) 22(1) Bombay Cotton Miis Vs. Compound, Dattaram Lad Path Kalachowky, Mumbai - 400033 (Pan: Aaacw2493G) (Appellant) (Respondent) Assessment Year: 2014-15 Deputy Commissioner Of Income Western India Garments Tax - 8(2)(1), Private Limited Mumbai 22(1) Bombay Cotton Miis Compound, Vs. Dattaram Lad Path Kalachowky, Mumbai - 400033 (Pan: Aaacw2493G) (Appellant) (Respondent) Present For: Assessee : Shri Dharan Gandhi, Advocate Revenue : Shri Arun Kanti Datta, Cit Dr Date Of Hearing : 03.07.2025 Date Of Pronouncement : 22.09.2025 O R D E R Pico Capital Pvt Ltd. & Western India Garments Pvt Ltd. Ay 2014-15 Per Girish Agrawal: These Two Appeals Filed By Assessee & Revenue Are Against The Order Of Ld. Cit(A), National Faceless Appeal Centre (Nfac), Delhi, Vide Order No. Itba/Nfac/S/250/2023-24/1056675304(1), Dated 29.09.2023 Passed Against The Assessment Order By Dcit, Circle - 8(3)(2), Mumbai, U/S. 143(3) Of The Income-Tax Act, 1961 (Hereinafter Referred To As The “Act”), Dated 13.12.2016 For Assessment Year 2014- 15. 2. Grounds Taken By The Assessee Are Reproduced As Under: 1. The Ld. Cit(A), Nfac Has Erred In Confirming The Disallowance Of Rs. 13,52,543/- Made U/S 14A R.W.R. 8D Of The Rules Over & Above The Disallowance Of Rs. 11,02,185/- Made By The Appellant. 2. The Assessment Order U/S 143(3) Of The Act, Dated 13.12.2016 Is Bad In Law As The Same Has Been Passed In The Name Of The Non-Existent Person. 3. The Ld. Ao, Has Erred In The Levying Interest Under Section 234B Of The Act. 4. The Ld. Ao Erred In Initiating Penalty Proceedings U/S 271(1)(C) Of The Act.

For Appellant: Shri Dharan Gandhi, AdvocateFor Respondent: Shri Arun Kanti Datta, CIT DR
Section 143(3)Section 14ASection 234BSection 271(1)(c)Section 36(1)(vii)

debt. or part thereof which is written off as irrecoverable in the accounts of the assessee for the previous year  Section 36(2)10 provides as follows “In making any deduction for a bad debt or part thereof the following provisions shall apply- (i) no such deduction shall be allowed

Pico Capital Private Limited (Successor in Interest of M/S Western India Garments Private Limited ), Mumbai vs. Deputy Commissioner of Income Tax-8(3)(2), Mumbai

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

ITA 4007/MUM/2023[2014-15]Status: DisposedITAT Mumbai22 Sept 2025AY 2014-15

Bench: Smt. Beena Pillai & Shri Girish Agrawalassessment Year: 2014-15 Pico Capital Private Limited Deputy Commissioner Of (Successor In Interest Of M/S Income Tax-8(3)(2), Western India Garments Private Mumbai Limited ) 22(1) Bombay Cotton Miis Vs. Compound, Dattaram Lad Path Kalachowky, Mumbai - 400033 (Pan: Aaacw2493G) (Appellant) (Respondent) Assessment Year: 2014-15 Deputy Commissioner Of Income Western India Garments Tax - 8(2)(1), Private Limited Mumbai 22(1) Bombay Cotton Miis Compound, Vs. Dattaram Lad Path Kalachowky, Mumbai - 400033 (Pan: Aaacw2493G) (Appellant) (Respondent) Present For: Assessee : Shri Dharan Gandhi, Advocate Revenue : Shri Arun Kanti Datta, Cit Dr Date Of Hearing : 03.07.2025 Date Of Pronouncement : 22.09.2025 O R D E R Pico Capital Pvt Ltd. & Western India Garments Pvt Ltd. Ay 2014-15 Per Girish Agrawal: These Two Appeals Filed By Assessee & Revenue Are Against The Order Of Ld. Cit(A), National Faceless Appeal Centre (Nfac), Delhi, Vide Order No. Itba/Nfac/S/250/2023-24/1056675304(1), Dated 29.09.2023 Passed Against The Assessment Order By Dcit, Circle - 8(3)(2), Mumbai, U/S. 143(3) Of The Income-Tax Act, 1961 (Hereinafter Referred To As The “Act”), Dated 13.12.2016 For Assessment Year 2014- 15. 2. Grounds Taken By The Assessee Are Reproduced As Under: 1. The Ld. Cit(A), Nfac Has Erred In Confirming The Disallowance Of Rs. 13,52,543/- Made U/S 14A R.W.R. 8D Of The Rules Over & Above The Disallowance Of Rs. 11,02,185/- Made By The Appellant. 2. The Assessment Order U/S 143(3) Of The Act, Dated 13.12.2016 Is Bad In Law As The Same Has Been Passed In The Name Of The Non-Existent Person. 3. The Ld. Ao, Has Erred In The Levying Interest Under Section 234B Of The Act. 4. The Ld. Ao Erred In Initiating Penalty Proceedings U/S 271(1)(C) Of The Act.

For Appellant: Shri Dharan Gandhi, AdvocateFor Respondent: Shri Arun Kanti Datta, CIT DR
Section 143(3)Section 14ASection 234BSection 271(1)(c)Section 36(1)(vii)

debt. or part thereof which is written off as irrecoverable in the accounts of the assessee for the previous year  Section 36(2)10 provides as follows “In making any deduction for a bad debt or part thereof the following provisions shall apply- (i) no such deduction shall be allowed