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“Section 36(1)”

Section References (mined)Section 36Section 36(1)3,872 judgments

The decision most relied on for Section 36(1) is CIT v. Reliance Utilities & Power Ltd. (313 ITR 340), cited in 2,118 judgments on BharatTax.

Leading authorities on Section 36(1)

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).

S.A. Builders Ltd. v. CIT
288 ITR 1 · 2007 · Supreme Court
1,484
citing judgments

Interest paid on borrowed funds cannot be disallowed merely because the assessee made interest-free advances, provided those advances were made for business purposes and commercial expediency. The Revenue cannot dictate a businessman's commercial decisions, but the assessee bears the onus to prove the business expediency.

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. HDFC Bank Ltd.
366 ITR 505 · 2014 · High Court
1,261
citing judgments

When an assessee possesses interest-free funds sufficient to cover investments yielding tax-free income, it is presumed that such investments were made from these interest-free funds, precluding disallowance of interest expenditure under Section 14A.

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.

Judgments citing Section 36(1)

The Dy.CIT, Circle-3(1)(1)., Ahmedabad vs. N.K. Industries Ltd., Ahmedabad

In the result, the appeal of the assessee on this ground is allowed

ITA 443/AHD/2023[2013-14]Status: DisposedITAT Ahmedabad25 Apr 2025AY 2013-14

Bench: Dr. B.R.R. Kumarms. Suchitra Kamble

For Appellant: NK Industries Ltd (Cross Appeals)
Section 250

computing the income under the head "profits and gains of business or profession", as per the provisions of the Act. 42. But, Section 36(1)(iii) makes a distinction. The amount of interest paid in respect of capital borrowed for the purpose of business or profession is allowed as deduction ... under Section 36(1)(iii), in computing the income referred to in Section 28. But, the proviso thereunder states that any amount of interest paid in respect of capital borrowed for acquisition of an asset for extension of existing business or profession, whether capitalised in the books of account

The Dy.CIT, Circle-3(1)(1)., Ahmedabad vs. N.K. Industries Ltd., Ahmedabad

In the result, the appeal of the assessee on this ground is allowed

ITA 442/AHD/2023[2010-11]Status: DisposedITAT Ahmedabad25 Apr 2025AY 2010-11

Bench: Dr. B.R.R. Kumarms. Suchitra Kamble

For Appellant: NK Industries Ltd (Cross Appeals)
Section 250

computing the income under the head "profits and gains of business or profession", as per the provisions of the Act. 42. But, Section 36(1)(iii) makes a distinction. The amount of interest paid in respect of capital borrowed for the purpose of business or profession is allowed as deduction ... under Section 36(1)(iii), in computing the income referred to in Section 28. But, the proviso thereunder states that any amount of interest paid in respect of capital borrowed for acquisition of an asset for extension of existing business or profession, whether capitalised in the books of account

Schott Glass India Private Liited, Mumbai vs. DCIT 3(2)(1), Mumbai

Appeal is allowed

ITA 6118/MUM/2024[2022-23]Status: DisposedITAT Mumbai25 Apr 2025AY 2022-23

Bench: Shri Om Prakash Kant (Am) & Shri Raj Kumar Chauhan (Jm) Schott Glass India Private Ltd. Dcit-3(2)(1) 203, 2Nd Floor, Dynasty A Wing Aayakar Bhavan Andheri Kurla Road, Andheri Vs. M.K. Road East, Mumbai-400 059. Mumbai-400 020. Pan : Aadcs8583L Appellant Respondent

For Appellant: Shri Vijay Mehta & ShriFor Respondent: Ms. Kanupriya Damor
Section 143(1)Section 2(24)(x)Section 234CSection 36(1)(va)

assessee/appellant filed appeal before the Ld. CIT(A), who has dismissed the same observing that the said amount needs to be disallowed under section 36(1)(va) read with section 2(24)(x) of the Act as the said amount which is employees’ contribution towards Provident Fund has not been ... thus submitted that the assessee was prevented from making online payment within stipulated time due to website glitches and therefore, the disallowance under Section 36(1)(va) is not justified in the peculiar circumstances owing to doctrine of impossibility. 6 Schott Glass India Pvt. Ltd. 3.1 It was contended that

Cobol Technologies P.Ltd, New Delhi vs. ACIT, Central Circle-18, New Delhi

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

ITA 5505/DEL/2018[2014-15]Status: DisposedITAT Delhi25 Apr 2025AY 2014-15

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

claim by documentary evidences that 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

Kamineni Health Services Private Limited, Hyderabad vs. ACIT, Circle - 2(1), Hyderabad

In the result, appeal of the Assessee is partly allowed

ITA 406/HYD/2023[2016-17]Status: DisposedITAT Hyderabad24 Apr 2025AY 2016-17

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

For Appellant: Shri Sashank Dundu, AdvocateFor Respondent: Shri Srinath Sadanala, Sr. AR
Section 142(1)Section 143(1)Section 143(2)Section 36(1)(iii)

known as M/s. Kamineni Heath Care Pvt Ltd and thus the same cannot be treated on par with advance/loan within the meaning of section 36(1)(iii) of the Act. 3. In the alternative, the NFAC ought to have noticed that the appellant had common funds out of which investment ... financial institutions to that extent cannot be held to have been used for business purposes and no deduction accordingly can be permitted under section 36(1)(iii) of the I.T. Act and accordingly, the Assessing Officer disallowed the interest expenses [to the extent of 12% on Rs.7

Fca India Automobiles Private Limited (Surviving Entity After the Merger of Pca Motors Pvt Ltd), Pune vs. Assessment Unit, Income Tax Department, National Faceless Assessment Centre

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

ITA 1781/PUN/2024[AY 2020-21]Status: DisposedITAT Pune23 Apr 2025

Bench: SHRI MANISH BORAD (Accountant Member), SHRI VINAY BHAMORE (Judicial Member)

For Appellant: Shri Siddhesh ChauguleFor Respondent: Ms. Shilpa N. C
Section 10ASection 143(1)Section 143(3)Section 250Section 253Section 36(1)(va)Section 37

addition made in intimation order under section 143(1) of the Act amounting to INR 4,297,560 on account of disallowance under section 36(1)(va) and section 37 of the Act (i.e. disallowed twice) even though the Appellant had already considered the same as disallowance in its return

Deputy Commissioner of Income Tax, Pune vs. Patson Agro Exports Private Limited, Pune City

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

ITA 1404/PUN/2023[2018-19]Status: DisposedITAT Pune23 Apr 2025AY 2018-19

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2018-19

For Appellant: Shri Kishor B PhadkeFor Respondent: Shri Ajay Kumar Keshari – CIT
Section 143(2)Section 41(1)

facts of the case as well as submissions filed by the appellant. I find force in the arguments of the Appellant. The section 36(1)(vii) basically stipulates two conditions for allowing the deduction for write-off as bad debt:-  The amount has been taken into account in computing ... INDIA in the case of T.R.F. Ltd. v. Commissioner of Income-tax, [2010] 190 Taxman 391 (SC) wherein it was held as under- Section 36(1)(vii) of the Income-tax Act, 1961-Bad debts - Assessment years 1990-91, 1993-94 and 1994-95 - Whether after 1

Bajaj Hindusthan Sugar Limited, Mumbai vs. Deputy Director of Income Tax, CPC

In the result, the appeal of the assessee is dismissed

ITA 814/MUM/2025[2023-24]Status: DisposedITAT Mumbai23 Apr 2025AY 2023-24

Bench: Shri Narender Kumar Choudhry & Shri Prabhash Shankar

For Appellant: Shri Kirit Kamdar,ARFor Respondent: Shri Leyaqat Ali Aafiqui (Sr. AR)
Section 143(1)Section 143(1)(a)Section 143(3)Section 37Section 37(1)Section 7Q

take its nature from the P a g e | 5 A.Y. 2023-24 Bajaj Hindustan Sugar Limited principal in terms of provisions of Section 36(1)(va) with respect to any sum received by the assessee from any of its employees to which provision of Section 2 (24)(x) applied ... employees’ account in the relevant fund or funds on or before the ‘due date’, the assessee was entitled to the deduction. Explanation to Section 36(1)(va) made it clear that for the purpose of that provision, “due date” meant the date by which the assessee, as an employer

Deputy Commissioner of Income Tax Circle 1(1)(1), Vadodara vs. Ami Life Science Private Limited, Vadodara

In the result, the appeal of the Department is dismissed

ITA 18/AHD/2025[2017-18]Status: DisposedITAT Ahmedabad22 Apr 2025AY 2017-18

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

For Appellant: Shri Abbas Gulamhusainwala, A.RFor Respondent: Shri Kavam Limbasiya, Sr. DR
Section 36(1)(ii)

avoid payment of dividend distribution tax and accordingly, the aforesaid payment of Rs.1,90,85,522/- was disallowed by the Assessing Officer under Section 36(1)(ii) of the Act. 4. In appeal, Ld. CIT(A) observed that recently the ITAT Ahmedabad in assessee's own case, deleted similar addition ... Based on the facts and judicial precedents, we hold that the commission paid to Shri Girish Chovatia is an allowable business expenditure under section 36(1)(ii). Therefore, the disallowance made by the AO and confirmed by the Ld.CIT(A) is deleted. As the issue under dispute is squarely covered

Ssb Contractual Services Private Limited, Nayagaon vs. ITO Ward 6(1), Mohali

In the result, appeal of the assessee is dismissed

ITA 342/CHANDI/2024[2019-20]Status: DisposedITAT Chandigarh21 Apr 2025AY 2019-20

Bench: Shri Rajpal Yadav & Shri Manoj Kumar Aggarwal

For Appellant: Shri Parikshit Aggarwal, CAFor Respondent: Dr. Ranjit Kaur, Addl. CIT Sr.DR
Section 36(1)(va)

single issue namely, ld. A.Y.2019-20 2 CIT(A) has erred in confirming the disallowance of Rs.24,95,732/- which was made under Section 36(1)(va) of the Income Tax Act. The assessee was unable to pay employees’ contribution to respective ESI/PF Accounts within the due date, therefore, following

Shakti Hormann Private Limited, Hyderabad vs. DCIT Circle -3(1), Hyderabad

In the result, appeals filed by the assessee for both the assessment years 2017-18 and 2018-19 are partly allowed

ITA 452/HYD/2022[2018-19]Status: DisposedITAT Hyderabad21 Apr 2025AY 2018-19

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं /Ita-Tp No.451/Hyd/2022 & 452/Hyd/2022 (निर्धारण वर्ा/Assessment Year: 2017-18 & 2018-19) Shakti Hormann Private Vs. Asst.Commissioner Of Limited Income Tax Hyderabad Circle-3(1) [Pan : Aadcs4024Q] Hyderabad (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Shri P.Murali Mohan Rao, Ar रधजस् व द्वधरध/Revenue By: Shri B.Bala Krishna, Cit-Dr सुिवधई की तधरीख/Date Of Hearing: 15/04/2025 घोर्णध की तधरीख/ 21/04/2025 Date Of Pronouncement: आदेश / Order Per Vijay Pal Rao: These Appeals Filed By The Assessee Are Directed Against The Assessment Orders Dated 21.07.2022 & 28.07.2022 Passed U/S 143(3) R.W.S. 144C(13) Of The Income Tax Act, 1961 (“The Act”) In Pursuant To The Directions Of The Dispute Resolution Panel (“The Drp”) U/S 144C(5) Of The Act For The Assessment Year 2017-18 & 2018-19 Respectively. 2. For The Assessment Year 2017-18, The Assessee Has Raised The Following Grounds Of Appeal :

For Appellant: Shri P.Murali Mohan Rao, ARFor Respondent: Shri B.Bala Krishna, CIT-DR
Section 143(3)Section 144C(5)Section 92C

that all the payments in relation to the prescribed in the Act. 10.3. The Ld. A.O erred in making the additions not considering section 36(1)(va) r.w.s 43B of the Act, that expenditure is allowable if paid within due date of filing return of income

Dy. Commissioner of Income Tax, Circle-1(1), Hyderabad vs. Union Bank of India, Hyderabad

In the result, the appeal of revenue is partly allowed for statistical

ITA 316/HYD/2019[2015-16]Status: DisposedITAT Hyderabad21 Apr 2025AY 2015-16
For Appellant: Shri S. Ananthan, C.A. &For Respondent: Ms. M Narmada, CIT-DR
Section 143(3)Section 14ASection 36(1)Section 36(1)(vii)Section 36(1)(viia)Section 36(1)(viii)Section 36(1)(vila)

their books of account and finally claimed deduction of Rs.1485,43,30,689/- in their computation of income as per the provisions of section 36(1)(viia) of the Act. However, only due to the difference in nomenclature of the account i.e. “provision for NPA” instead of “provision for doubtful ... aside the issue to the file of Ld. AO for recalculation. 11. In rejoinder, the Ld. AR invited our attention to provision of section 36(1)(viia) of the Act and submitted that, there is no requirement under the Act to consider the amount of security before making any provision

Union Bank of India (Erstwhile-Andhra Bank), Mumbai vs. Dy. Commissioner of Income Tax, Circle-1(1), Hyderabad

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

ITA 193/HYD/2019[2015-16]Status: DisposedITAT Hyderabad21 Apr 2025AY 2015-16

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdia

For Appellant: Shri S. Ananthan, C.A. &For Respondent: Ms. M Narmada, CIT-DR
Section 143(3)Section 14ASection 36(1)Section 36(1)(vii)Section 36(1)(viia)Section 36(1)(viii)Section 36(1)(vila)

their books of account and finally claimed deduction of Rs.1485,43,30,689/- in their computation of income as per the provisions of section 36(1)(viia) of the Act. However, only due to the difference in nomenclature of the account i.e. “provision for NPA” instead of “provision for doubtful ... aside the issue to the file of Ld. AO for recalculation. 11. In rejoinder, the Ld. AR invited our attention to provision of section 36(1)(viia) of the Act and submitted that, there is no requirement under the Act to consider the amount of security before making any provision

ACIT, Circle-2(2)(1), Bangalore vs. Canara Bank, Bengaluru

ITA 2058/BANG/2024[2021-2022]Status: DisposedITAT Bangalore21 Apr 2025AY 2021-2022

Bench: Shri. Laxmi Prasad Sahu & Shri. Keshav Dubey

For Appellant: Shri. Vishal Bhat, CA
Section 11Section 115JSection 129Section 143(1)(a)Section 154

IN INCOME TAX APPELLATE TRIBUNAL "A" BENCH : BANGALORE BEFORE SHRI. LAXMI PRASAD SAHU, ACCOUNTANT MEMBER AND SHRI. KESHAV DUBEY, JUDICIAL

DCIT 2 2 1, Mumbai vs. Yes Bank Limited, Mumbai

In the result, the appeal of the assessee bearing ITA No

ITA 992/MUM/2025[2020-21]Status: DisposedITAT Mumbai21 Apr 2025AY 2020-21

Bench: Shrinarendra Kumar Billaiya & Shri Anikesh Banerjeeyes Bank Limited Vs Additional Commissioner Of Income Yes Bank House, 8Th Floor, Tax (Appeals), Panchkula Prabhat Colony, Off Western Express Highway, Santacruz East, Mumbai-400 055 Pan : Aaacy2068D Appellant Respondent Additional Commissioner Of Vs Yes Bank Limited Yes Bank House, 8Th Floor Income Tax (Appeals), Panchkula Prabhat Colony, Off Western Express Highway, Santacruz East, Mumbai-400 055 Pan : Aaacy2068D Appellant Respondent

For Appellant: Shri Yogesh Thard &Ms.Vidhi SalotFor Respondent: Ms. Ramapriya Raghavan - CIT DR&
Section 139(1)Section 143(1)Section 234ASection 234CSection 250Section 36(1)(va)Section 43B

1) of the Act by the CPC, Bengaluru. During the processing, the CPC disallowed an amount of Rs.9,75,96,266/- claimed under Section 36(1)(va) of the Act, representing employees’ contributions to EPF and ESI, which had been deposited beyond the due dates prescribed under the respective statutes ... deleted the addition of Rs.30crore made under Section 43B but upheld the disallowance of Rs.9,75,96,266/- under Section 36(1)(va), as well as the interest levied under Section 234C. Being dissatisfied with the order, both the assessee and the revenue have filed appeals before us. ITA 1093/Mum/2025

Yes Bank Limited, Mumbai vs. Additional Commissioner of Income Tax (Appeals), Panchkula

In the result, the appeal of the assessee bearing ITA No

ITA 1093/MUM/2025[2020-21]Status: DisposedITAT Mumbai21 Apr 2025AY 2020-21

Bench: Shrinarendra Kumar Billaiya & Shri Anikesh Banerjeeyes Bank Limited Vs Additional Commissioner Of Income Yes Bank House, 8Th Floor, Tax (Appeals), Panchkula Prabhat Colony, Off Western Express Highway, Santacruz East, Mumbai-400 055 Pan : Aaacy2068D Appellant Respondent Additional Commissioner Of Vs Yes Bank Limited Yes Bank House, 8Th Floor Income Tax (Appeals), Panchkula Prabhat Colony, Off Western Express Highway, Santacruz East, Mumbai-400 055 Pan : Aaacy2068D Appellant Respondent

For Appellant: Shri Yogesh Thard &Ms.Vidhi SalotFor Respondent: Ms. Ramapriya Raghavan - CIT DR&
Section 139(1)Section 143(1)Section 234ASection 234CSection 250Section 36(1)(va)Section 43B

1) of the Act by the CPC, Bengaluru. During the processing, the CPC disallowed an amount of Rs.9,75,96,266/- claimed under Section 36(1)(va) of the Act, representing employees’ contributions to EPF and ESI, which had been deposited beyond the due dates prescribed under the respective statutes ... deleted the addition of Rs.30crore made under Section 43B but upheld the disallowance of Rs.9,75,96,266/- under Section 36(1)(va), as well as the interest levied under Section 234C. Being dissatisfied with the order, both the assessee and the revenue have filed appeals before us. ITA 1093/Mum/2025

United Overseas Bank Limited, Mumbai vs. Assistant Commissioner of Income-Tax, Mumbai

The appeal of the assessee is partly allowed

ITA 3486/MUM/2023[2020-21]Status: DisposedITAT Mumbai21 Apr 2025AY 2020-21

Bench: Shri Pawan Singh, Jm & Ms Padmavathy S, Am

For Appellant: Shri Madhur Agarwal, ARFor Respondent: 09.04.2025
Section 143(2)Section 143(3)Section 144Section 144C(13)Section 147Section 153Section 270ASection 37Section 44C

Average Adjusted total income (A) 23,443,997 Actual expenditure incurred (B) 1,003,222 Deduction allowable under section 36(1)(viia) of the Act [Lower 1,003,222 of (A) or (B)] 5. The ld. AR in this regard relied on the order of the Co-ordinate Bench

Honeywell International India Private Limited, Delhi vs. DCIT Circle-10(1), Delhi

Appeal is partly allowed for statistical purposes

ITA 2933/DEL/2024[2018-19]Status: DisposedITAT Delhi17 Apr 2025AY 2018-19

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwalassessment Year: 2018-19 M/S. Honeywell International Vs. Dcit, India Pvt. Ltd., Circle-10(1), 1120-21, 11Th Floor, Tower-A, Delhi Dlf Tower, Jasola District Centre, New Friends Colony, South-East Delhi, New Delhi Pan: Aabca7954K (Appellant) (Respondent) Assessee By Sh. S.K. Aggarwal, Ca Department By Sh. Rajesh Kumar Dhanesta, Sr. Dr Date Of Hearing 17.04.2025 Date Of Pronouncement 17.04.2025 Order

Section 143(1)Section 250Section 253(1)(a)Section 36(1)Section 36(1)(va)Section 40

Audit Report on income tax e filing portal. 2 | P a g e Disallowance of labour Welfare Fund of INR 8,930 under section 36(1) (va) of the Act Poupe Ald 5. On the facts and circumstances of the case ... terms, as per law. 4. Learned counsel next submits that the assessee had suo motu disallowed the latter sum of Rs.8,930/- under section 36(1)(va) of the Act, and, it amounts to a double disallowance/addition therefore. 5. Faced with this situation, we direct the learned Assessing Officer

Manoj Kumar Jain, Raipur vs. Income Tax Officer, Ward-1(2), Raipur

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

ITA 77/RPR/2025[2018-19]Status: DisposedITAT Raipur16 Apr 2025AY 2018-19

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita No.77/Rpr/2025 "नधा"रण वष" /Assessment Year : 2018-19 Manoj Kumar Jain M/S. Vidyashree Trading, Ghul Ghul, Tilda, Neora, Raipur (C.G.)-493 114 Pan: Achpj6480G .......अपीलाथ" / Appellant बनाम / V/S. The Income Tax Officer, Ward-1(2), Raipur (C.G) ……""यथ" / Respondent

For Appellant: Shri Ravi Agrawal, CAFor Respondent: Dr. Priyanka Patel, Sr. DR
Section 143(1)Section 143(1)(a)Section 250Section 36(1)(iii)

income from other sources, it disallowed the deduction for interest on unsecured loans. The appellant stated that this deduction was allowable under Section 36(1)(iii) of the Income Tax Act. He came to know of the disallowance only when contacted by the department regarding the demand. The appellant argued ... that the interest on unsecured loans is a valid deduction under Section 36(1)(iii), as it relates to capital borrowed for business purposes. He maintained two sets of books: the main books and the firm's books. The main books included the capital of the firm as an investment

Oakton Global Technology Services Centre (I) Private Limited, Hyderabad vs. Dy. Commissioner of Income Tax, Circle-16(2), Hyderabad

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

ITA 32/HYD/2019[2014-15]Status: DisposedITAT Hyderabad16 Apr 2025AY 2014-15

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdia

For Appellant: Shri Ravi Bharadawaj, C.AFor Respondent: Shri B. Bala Krishna, CIT-DR
Section 143(3)Section 92B

also gone through the record in the light of the submissions made by either side. We have gone through the provisions of section 36(1)(vii) of the Act, which specifically states that, any provision for bad and doubtful debts is not an allowable expenditure unless it qualifies under