“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)

Kausalya Agro Forms & Developers Private Limited, Hyderabad vs. Dy. Commissioner of Income Tax, Central Circle-2(3), Hyderabad

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

ITA 676/HYD/2020[2017-18]Status: DisposedITAT Hyderabad04 Sept 2024AY 2017-18

Bench: Shri Laliet Kumar, Hon’Ble & Shri Manjunatha G, Hon’Ble

For Appellant: Shri S. Rama Rao, AdvocateFor Respondent: Ms. Reema Yadav, Sr.AR

Section 132Section 143(3)Section 147Section 148Section 14ASection 36(1)(iii)

directed the Tribunal to dispose of the appeal on the limited grounds urged by the appellant, namely, disallowance of interest expenditure under Section 36(1)(iii) of the Act to the extent disallowed by the first appellate authority as well as the validity of the reassessment proceedings. 6. The first ... directed the Tribunal to hear the appeals before it on the limited grounds urged by the appellant, namely, disallowance of finance charges under Section 36(1)(iii) of the Act to the extent disallowed by the first appellate authority as well as the validity of the reassessment proceedings

Kausalya Agro Forms & Developers Private Limited, Hyderabad vs. Dy. Commissioner of Income Tax, Central Circle-2(3), Hyderabad

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

ITA 675/HYD/2020[2014-15]Status: DisposedITAT Hyderabad04 Sept 2024AY 2014-15

Bench: Shri Laliet Kumar, Hon’Ble & Shri Manjunatha G, Hon’Ble

For Appellant: Shri S. Rama Rao, AdvocateFor Respondent: Ms. Reema Yadav, Sr.AR

Section 132Section 143(3)Section 147Section 148Section 14ASection 36(1)(iii)

Indur Developers and Agencies Private Limited, Vijayawada vs. Dy. Commissioner of Income Tax, Central Circle-2(3), Hyderabad

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

ITA 672/HYD/2020[2016-17]Status: DisposedITAT Hyderabad04 Sept 2024AY 2016-17

Bench: Shri Laliet Kumar, Hon’Ble & Shri Manjunatha G, Hon’Ble

For Appellant: Shri S. Ramarao, AdvocateFor Respondent: Ms. Reema Yadav, Sr.AR

Section 132Section 143(3)Section 147Section 148Section 14ASection 36(1)(iii)

directed the Tribunal to dispose of the appeal on the limited grounds urged by the appellant, namely, disallowance of interest expenditure under Section 36(1)(iii) of the Act to the extent disallowed by the first appellate authority as well as the validity of the reassessment proceedings. 6. The first ... disallowed the interest debited under finance charges and carried forward to work-in-progress amounting to Rs.1,31,51,977/- under Section 36(1)(iii) of the Income Tax Act, 1961. 9. The assessee carried the matter in appeal before the ld. CIT(A). Before

Indur Avenues and Foods Private Limited, Nizamabad vs. Dy. Commissioner of Income Tax, Central Circle-2(3), Hyderabad

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

ITA 667/HYD/2020[2013-14]Status: DisposedITAT Hyderabad04 Sept 2024AY 2013-14

Bench: Shri Laliet Kumar, Hon’Ble & Shri Manjunatha G, Hon’Ble

For Appellant: Shri S. Ramarao, AdvocateFor Respondent: Ms. Reema Yadav, Sr.AR

Section 132Section 143(3)Section 147Section 148Section 14ASection 36(1)(iii)

directed the Tribunal to dispose of the appeal on the limited grounds urged by the appellant, namely, disallowance of interest expenditure under Section 36(1)(iii) of the Act to the extent disallowed by the first appellate authority as well as the validity of the reassessment proceedings. 6. The first ... disallowed the interest debited under finance charges and carried forward to work-in-progress amounting to Rs.1,31,51,977/- under Section 36(1)(iii) of the Income Tax Act, 1961. 9. The assessee carried the matter in appeal before the ld. CIT(A). Before

Indur Avenues and Foods Private Limited, Nizamabad vs. Dy. Commissioner of Income Tax, Central Circle-2(3), Hyderabad

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

ITA 666/HYD/2020[2012-13]Status: DisposedITAT Hyderabad04 Sept 2024AY 2012-13

Bench: Shri Laliet Kumar, Hon’Ble & Shri Manjunatha G, Hon’Ble

For Appellant: Shri S. Ramarao, AdvocateFor Respondent: Ms. Reema Yadav, Sr.AR

Section 132Section 143(3)Section 147Section 148Section 14ASection 36(1)(iii)

directed the Tribunal to dispose of the appeal on the limited grounds urged by the appellant, namely, disallowance of interest expenditure under Section 36(1)(iii) of the Act to the extent disallowed by the first appellate authority as well as the validity of the reassessment proceedings. 6. The first ... disallowed the interest debited under finance charges and carried forward to work-in-progress amounting to Rs.1,31,51,977/- under Section 36(1)(iii) of the Income Tax Act, 1961. 9. The assessee carried the matter in appeal before the ld. CIT(A). Before

Ujwala Publications and Developers Private Limited, Warangal vs. Dy. Commissioner of Income Tax, Central Circle-2(3), Hyderabad

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

ITA 658/HYD/2020[2012-13]Status: DisposedITAT Hyderabad04 Sept 2024AY 2012-13

Bench: Shri Laliet Kumar, Hon’Ble & Shri Manjunatha G, Hon’Bleassessment Year: 2012-13 Ujwala Publications & Vs. The Deputy Commissioner Of Developers Pvt. Ltd. Income Tax, Warangal. Central Circle – 2(3), Hyderabad. Pan – Aaacu6544J (Appellant / Assessee) (Respondent) Assessee By: Shri S. Ramarao, Advocate Revenue By: Ms. Reema Yadav, Sr.Ar. Date Of Hearing: 31.07.2024 Date Of Pronouncement: 04.09.2024

For Appellant: Shri S. Ramarao, AdvocateFor Respondent: Ms. Reema Yadav, Sr.AR

Section 132Section 143(3)Section 147Section 148Section 14ASection 36(1)(iii)

Nalgonda Realtors Private Limited, Hyderabad vs. Dy. Commissioner of Income Tax, Central Circle-2(3), Hyderabad

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

ITA 657/HYD/2020[2017-18]Status: DisposedITAT Hyderabad04 Sept 2024AY 2017-18

Bench: Shri Laliet Kumar, Hon’Ble & Shri Manjunatha G, Hon’Ble

For Appellant: Shri S. Ramarao, AdvocateFor Respondent: Ms. Reema Yadav, Sr.AR

Section 132Section 143(3)Section 147Section 148Section 14ASection 36(1)(iii)

directed the Tribunal to dispose of the appeal on the limited grounds urged by the appellant, namely, disallowance of interest expenditure under Section 36(1)(iii) of the Act to the extent disallowed by the first appellate authority as well as the validity of the reassessment proceedings. 6. The first ... directed the Tribunal to dispose of the appeal on the limited grounds urged by the appellant, namely, disallowance of interest expenditure under Section 36(1)(iii) of the Act to the extent disallowed by the first appellate authority as well as the validity of the reassessment proceedings. 18. The first

Nalgonda Realtors Private Limited, Hyderabad vs. Dy. Commissioner of Income Tax, Central Circle-2(3), Hyderabad

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

ITA 656/HYD/2020[2013-14]Status: DisposedITAT Hyderabad04 Sept 2024AY 2013-14

Bench: Shri Laliet Kumar, Hon’Ble & Shri Manjunatha G, Hon’Ble

For Appellant: Shri S. Ramarao, AdvocateFor Respondent: Ms. Reema Yadav, Sr.AR

Section 132Section 143(3)Section 147Section 148Section 14ASection 36(1)(iii)

directed the Tribunal to dispose of the appeal on the limited grounds urged by the appellant, namely, disallowance of interest expenditure under Section 36(1)(iii) of the Act to the extent disallowed by the first appellate authority as well as the validity of the reassessment proceedings. 6. The first ... directed the Tribunal to dispose of the appeal on the limited grounds urged by the appellant, namely, disallowance of interest expenditure under Section 36(1)(iii) of the Act to the extent disallowed by the first appellate authority as well as the validity of the reassessment proceedings. 18. The first

Nalgonda Realtors Private Limited, Secunderabad vs. Dy. Commissioner of Income Tax, Central Circle-2(3), Hyderabad

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

ITA 655/HYD/2020[2012-13]Status: DisposedITAT Hyderabad04 Sept 2024AY 2012-13

Bench: Shri Laliet Kumar, Hon’Ble & Shri Manjunatha G, Hon’Ble

For Appellant: Shri S. Ramarao, AdvocateFor Respondent: Ms. Reema Yadav, Sr.AR

Section 132Section 143(3)Section 147Section 148Section 14ASection 36(1)(iii)

directed the Tribunal to dispose of the appeal on the limited grounds urged by the appellant, namely, disallowance of interest expenditure under Section 36(1)(iii) of the Act to the extent disallowed by the first appellate authority as well as the validity of the reassessment proceedings. 6. The first ... directed the Tribunal to dispose of the appeal on the limited grounds urged by the appellant, namely, disallowance of interest expenditure under Section 36(1)(iii) of the Act to the extent disallowed by the first appellate authority as well as the validity of the reassessment proceedings. 18. The first

Kapil Food and Structure Private Limited, Hyderabad vs. Dy. Commissioner of Income Tax, Central Circle-2(3), Hyderabad

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

ITA 654/HYD/2020[2013-14]Status: DisposedITAT Hyderabad04 Sept 2024AY 2013-14

Bench: Shri Laliet Kumar, Hon’Ble & Shri Manjunatha G, Hon’Ble

For Appellant: Shri S. Ramarao, AdvocateFor Respondent: Ms. Reema Yadav, Sr.AR

Section 132Section 143(3)Section 147Section 148Section 14ASection 36(1)(iii)

directed the Tribunal to dispose of the appeal on the limited grounds urged by the appellant, namely, disallowance of interest expenditure under Section 36(1)(iii) of the Act to the extent disallowed by the first appellate authority as well as the validity of the reassessment proceedings. 6. The first ... directed the Tribunal to dispose of the appeal on the limited grounds urged by the appellant, namely, disallowance of interest expenditure under Section 36(1)(iii) of the Act to the extent disallowed by the first appellate authority as well as the validity of the reassessment proceedings. 17. The first

Kapil Property Developers Limited, Hanumakonda vs. Dy Commissioner of Income Tax, Hyderabad

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

ITA 652/HYD/2020[2013-14]Status: DisposedITAT Hyderabad04 Sept 2024AY 2013-14

Bench: Shri Laliet Kumar, Hon’Ble & Shri Manjunatha G, Hon’Ble

For Appellant: Shri S. Ramarao, AdvocateFor Respondent: Ms. Reema Yadav, Sr.AR

Section 132Section 143(3)Section 147Section 148Section 14ASection 36(1)(iii)

directed the Tribunal to dispose of the appeal on the limited grounds urged by the appellant, namely, disallowance of interest expenditure under Section 36(1)(iii) of the Act to the extent disallowed by the first appellate authority as well as the validity of the reassessment proceedings. 6. The first ... directed the Tribunal to dispose of the appeal on the limited grounds urged by the appellant, namely, disallowance of interest expenditure under Section 36(1)(iii) of the Act to the extent disallowed by the first appellate authority as well as the validity of the reassessment proceedings. 17. The first

Dakshin Infrastrctures Private Limited, Hyderabad vs. Dy. Commissioner of Income Tax, Central Circle-2(3), Hyderabad

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

ITA 651/HYD/2020[2012-13]Status: DisposedITAT Hyderabad04 Sept 2024AY 2012-13

Bench: Shri Laliet Kumar, Hon’Ble & Shri Manjunatha G, Hon’Bleassessment Year: 2012-13 Dakshin Infrastructures Pvt. Ltd. Vs. The Deputy Commissioner Of Hyderabad. Income Tax, Central Circle – 2(3), Pan – Aaccd4138P Hyderabad. (Appellant / Assessee) (Respondent) Assessee By: Shri S. Rama Rao, Advocate Revenue By: Ms. Reema Yadav, Sr.Ar. Date Of Hearing: 31.07.2024 Date Of Pronouncement: 04.09.2024

For Appellant: Shri S. Rama Rao, AdvocateFor Respondent: Ms. Reema Yadav, Sr.AR

Section 132Section 143(3)Section 14ASection 153ASection 36(1)(iii)

directed the Tribunal to hear the appeals before it on the limited grounds urged by the appellant, namely, disallowance of finance charges under Section 36(1)(iii) of the Act to the extent disallowed by the first appellate authority as well as the validity of the reassessment proceedings ... assessee's appeal is the disallowance of finance charges of Rs.1,91,95,429/- made by the AO under Section 36(1)(iii) of the Income Tax Act, 1961. During the course of the assessment proceedings, the AO noticed that the real estate companies of Kapil Group have been accepting

Assistant Commissioner of Income Tax Corporate Circle 1(1), Nungambakkam vs. Idfc Limited, Teynampet

In the result, both the appeals filed by the Revenue are dismissed

ITA 819/CHNY/2024[2016-17]Status: DisposedITAT Chennai04 Sept 2024AY 2016-17

Bench: Shri S.S. Viswanethra Ravi & Shri S.R. Raghunathaआयकर अपील सं./I.T.A. Nos.818 & 819/Chny/2024 िनधा"रण वष"/Assessment Year: 2016-17 The Assistant Commissioner Of Vs. Idfc Limited, 4Th Floor, Capitale Tower, No. 555, Income Tax, Corporate Circle 1(1), Anna Salai, Thiru Vi Ka Kudiyiruppu, Chennai 600 034. Teynampet, Chennai 600 018. [Pan:Aaaci2663N] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri V. Nandakumar, Cit ""थ" की ओर से/Respondent By : Shri Ketan Ved, C.A. सुनवाई की तारीख/ Date Of Hearing : 29.08.2024 घोषणा की तारीख /Date Of Pronouncement : 04.09.2024 आदेश /O R D E R Per S.S. Viswanethra Ravi: Both The Appeals Filed By The Revenue Are Directed Against Separate Orders Dated Both Dated 21.09.2022 Passed By The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre [Nfac], Delhi For The Assessment Year 2016-17. 2. Since The Issue Raised In Both The Appeals Are Similar Based On The Same Identical Facts, With The Consent Of The Both The Parties, We Proceed To Hear All These Appeals Together & Pass Consolidated Order For The Sake Of Convenience.

For Appellant: Shri V. Nandakumar, CITFor Respondent: Shri Ketan Ved, C.A

Section 143(3)Section 147Section 148Section 14ASection 36(1)(viia)Section 36(1)(viii)

Officer completed the reassessment by making, inter alia, addition on account of enhanced disallowance under section 14A read with Rule 8D, disallowance under section 36(1)(viii), enhanced disallowance under section 36(1)(viia) of the Act and determined the total income of the assessee ... hearing both the parties and on perusal of the reassessment order, we note that the Assessing officer proceeded to make various disallowances under sections 36(1)(viia), 36(1)(viii), 14A of the Act on sale of investment only on examination of computation of statement, which was already there

Assistant Commissioner of Income Tax Corporate Circle 1(1), Nungambakkam vs. Idfc Limited, Teynampet

In the result, both the appeals filed by the Revenue are dismissed

ITA 818/CHNY/2024[2016-17]Status: DisposedITAT Chennai04 Sept 2024AY 2016-17

For Appellant: Shri V. Nandakumar, CITFor Respondent: Shri Ketan Ved, C.A

Section 143(3)Section 147Section 148Section 14ASection 36(1)(viia)Section 36(1)(viii)

Chhotagovinpur and Bagbera Drinking Water Supply Project Limited, Chennai vs. ITO, Corp Ward 1(1), Chennai

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

ITA 1013/CHNY/2024[2018-19]Status: DisposedITAT Chennai04 Sept 2024AY 2018-19

Bench: Shri Aby T. Varkey & Shri Jagadishआयकर अपील सं./Ita No.1013/Chny/2024 िनधा"रणवष"/Assessment Year: 2018-19 V. M/S.Chhotagovindpur & Bagbera- The Ito, Drinking Water – Corporate Ward-1(3), Supply Project Ltd., Chennai. New No.136, G.R.Tower 4Th Floor, Nelson Manickam Road, Aminjikarai, Chennai-600 029. [Pan: Aagcc 0433 L] (अपीलाथ"/Appellant) (""यथ"/Respondent)

For Appellant: Shri R. Viswanathan, FCAFor Respondent: Shri R. Clement Ramesh

Section 144Section 36(1)Section 43BSection 801A

आयकर अपीलीय अिधकरण, ’सी’ "यायपीठ, चे"ई। IN THE INCOME TAX APPELLATE TRIBUNAL ‘C’ BENCH: CHENNAI "ी एबी टी. वक", "ाियक

Assistant Commissioner of Income Tax, Nagpur vs. M/S. Gupta Metallics & Power Ltd, Nagpur

In the result, appeal filed by the Revenue is dismissed

ITA 91/NAG/2022[2010-11]Status: DisposedITAT Nagpur02 Sept 2024AY 2010-11

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

For Appellant: Shri Rajesh LoyaFor Respondent: Shri Kailash C. Kanojiya

Section 132Section 132(4)

Assessing Officer. The funds from the discounted letter of credits are used for the purpose of business and is allowable under section 36(1)(iii) of the Act. There is no ground to interfere with the conclusions of the learned CIT(A). Hence, the ground raised by the Revenue

Assistant Commissioner of Income Tax, Kalyan vs. Vip Clothing Limited, Bhiwandi

In the result, the appeal of the Revenue and C

ITA 2247/MUM/2024[2012-13]Status: DisposedITAT Mumbai02 Sept 2024AY 2012-13

Bench: Ms Padmavathy S, Am & Shri Sandeep Singh Karhail, Jm

For Appellant: Shri Subodh Ratnaparkhi, AR

Section 143(3)Section 147Section 148Section 36Section 36(1)(vii)

sales made during the year and 3 ITA No. 2247 & C.O. 109/Mum/2024 Vip Clothing Ltd. does not fall within the provisions of section 36(1)(vii) of the Income Tax Act, 1961 ( the Act). The assessee filed the return of income in response to notice under section ... amount to a Provision or contingent liability but are admissible as Bad Debts and allowable as per the provisions of section 36(1) (vii) r.w.s 36(2) of the I. T. Act, 1961. Accordingly, the addition/disallowance made by the A.O is deleted and the Grounds of Appeal are Allowed

M/S Nova Iron and Steel Ltd., Chandigarh vs. DCIT, CC-1, Chandigarh

Appeal of the assessee is partly allowed

ITA 303/CHANDI/2023[2020-21]Status: DisposedITAT Chandigarh30 Aug 2024AY 2020-21

Bench: Filing Of Income Tax Return.

For Appellant: Shri Ashwani Kumar, CA and Ms. Deepali Aggarwal, C.AFor Respondent: Smt. Kusum Bansal, CIT DR

Section 139(5)Section 143(1)Section 143(1)(a)Section 250Section 253Section 36(1)(va)Section 43B

Centralised Processing Centre (CPC) Bengaluru while processing the return under section 143(1) unjustifiably made an addition of Rs. 51,42,946/- under section 36(1)(va) on account of late deposit of employees contribution to PF/ESI despite the fact that the same was duly paid before filing of Income

Chandan Singh Contractor, Bhopal vs. Commissioner of Income-Tax (Appeals), Delhi

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

ITA 348/IND/2024[2014-15]Status: DisposedITAT Indore30 Aug 2024AY 2014-15

Bench: Shri Vijay Pal Rao & Shri B.M. Biyanim/S Chandan Singh Contractor, Cit(A) ( Nfac), E-88/33 Basant Kunj, Delhi Vs. Arera Colony, Bhopal (Appellant / Assessee) (Respondent/ Revenue) Pan: Aaffc8954Q Assessee By Shri Gagan Tiwari, Ar Revenue By Shri Ashish Porwal, Sr.Dr Date Of Hearing 29.08.2024 Date Of Pronouncement 30.08.2024 O R D E R

Section 143(3)Section 144Section 148Section 250(6)Section 36(1)Section 36(1)(iii)

आयकर अपील"य अ"धकरण, इंदौर "यायपीठ, इंदौर IN THE INCOME TAX APPELLATE TRIBUNAL INDORE BENCH, INDORE BEFORE SHRI VIJAY

Premcem Gums Private Limited, Mumbai vs. DCIT 14(2)(2), Mumbai

Accordingly, Ground No. 3 raised by the Appellant is dismissed

ITA 633/MUM/2024[2014-15]Status: DisposedITAT Mumbai30 Aug 2024AY 2014-15

Bench: SHRI AMARJIT SINGH, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri Kirit SanghviFor Respondent: Shri HM Bhatt/Shri Raj Singh Meel

Section 143(3)Section 147Section 36(1)(vii)Section 36(1)(viii)

Appellant was assessed at INR 18,74,70,592/- after making disallowance of claim of deduction of INR 2,14,52,400/- under Section 36(1)(vii) of the Act in respect of bad debts written off during the relevant previous year. The appeal preferred by the Appellant before ... Motilal Oswal Commodities Broker Private Limited. Since the Assessee had claimed deduction of INR 2,14,52,400/- as bad debts under section 36(1)(viii) of the Income Tax Act, the Assessee was asked to provide explanation for the same. The Appellant has explained before the Assessing Officer that