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“Section 36(1)(vii)”

Section References (mined)Section 36Section 36(1)(vii)853 judgments

The decision most relied on for Section 36(1)(vii) is TRF Ltd. v. CIT (323 ITR 397), cited in 714 judgments on BharatTax.

Leading authorities on Section 36(1)(vii)

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.

Maxopp Investment Ltd. v. CIT
347 ITR 272 · 2012 · High Court
516
citing judgments

Disallowance under Section 14A cannot exceed the exempt income earned. The Assessing Officer must record satisfaction regarding the assessee's accounts before making any disallowance.

South Indian Bank Ltd. v. CIT
438 ITR 1 · 2021 · Supreme Court
508
citing judgments

The mixed fund theory is affirmed, holding that no disallowance of interest expenditure under Section 14A can be made if the assessee possesses sufficient non-interest bearing funds, such as capital and reserves, to cover investments made in tax-free securities.

Vijaya Bank v. CIT
323 ITR 166 · 2010 · Supreme Court
392
citing judgments

A provision for bad and doubtful debts debited to the profit and loss account and reduced from advances on the balance sheet constitutes a write-off for deduction purposes. This is true even if individual debtor accounts are not closed.

Southern Technologies Ltd. v. JCIT
320 ITR 577 · 2010 · Supreme Court
353
citing judgments

The case concerns the allowability of deductions for provisions made under Section 36 of the Income Tax Act, 1961, especially those related to bad and doubtful debts. It distinguishes such deductions from the recognition of interest income on non-performing assets (NPAs).

Calcutta Co. Ltd. v. CIT
37 ITR 1 · 1959 · Supreme Court
341
citing judgments

When following the mercantile system of accounting, provisions for liabilities made on a scientific and rational basis are allowable as deductions, even if their actual quantification and discharge are deferred to a future date.

Catholic Syrian Bank Ltd. v. CIT
343 ITR 270 · 2012 · Supreme Court
326
citing judgments

For a bad debt deduction under Section 36(1)(vii), the debt must be actually written off as irrecoverable in the assessee's accounts, distinct from merely making a provision for bad and doubtful debts. The assessee bears the onus to satisfy the conditions under both Section 36(1)(vii) and Section 36(2) of the Income-tax Act.

United Commercial Bank v. CIT
240 ITR 355 · 1999 · Supreme Court
314
citing judgments

Liabilities accrued on a notional basis are allowable as deductions under the mercantile system of accounting even if their exact quantification or discharge is deferred to a future date or if the demand itself is disputed.

Judgments citing Section 36(1)(vii)

Karnataka Housing Board, Bangalore vs. DCIT, Exemptions Cirlce-1, Bengaluru

ITA 169/BANG/2025[2012-13]Status: DisposedITAT Bangalore04 Aug 2025AY 2012-13

Bench: Shri Prashant Maharishi & Shri Soundararajan K.

For Appellant: Shri Padamchand Khincha, AdvocateFor Respondent: Smt. Nandini Das, CIT(DR)(ITAT), Bengaluru
Section 11Section 13(8)Section 143(3)Section 2(15)

debts' of Rs.18,10,68,604/-; and ii) in concluding that these expenses were not in the nature of irrecoverable debts covered within section 36(1)(vii). 7.2 Without prejudice to the above, even if the said amount is added back to the total income, the same is exempt from

Karnataka Housing Board, Bangalore vs. DCIT, Bangalore

ITA 1283/BANG/2016[2011-12]Status: DisposedITAT Bangalore04 Aug 2025AY 2011-12

Bench: Shri Prashant Maharishi & Shri Soundararajan K.

For Respondent: Date of hearing
Section 11Section 13(8)Section 143(3)Section 2(15)

debts' of Rs.18,10,68,604/-; and ii) in concluding that these expenses were not in the nature of irrecoverable debts covered within section 36(1)(vii). 7.2 Without prejudice to the above, even if the said amount is added back to the total income, the same is exempt from

Assistant Commissioner of Income Tax, Circle-25(1), Delhi vs. Unison Hotels Private Limited, Delhi

In the result, appeal of the Revenue is dismissed

ITA 4471/DEL/2024[2014-15]Status: DisposedITAT Delhi04 Aug 2025AY 2014-15

Bench: Ms.Madhumita Roy & Shri Manish Agarwal[Assessment Year : 2014-15] Acit, Vs Unison Hotels Pvt.Ltd., Cirlce-25(1), Plot No.2, Nelson Mandela Road, Delhi Vasant Kunj, Phase-2Nd, New Delhi-110070. Pan-Aaacu0455C Appellant Respondent Revenue By Shri Virender Kumar Singh, Sr.Dr Assessee By Ms. Kavita Jha, Sr.Adv., Shri Himanshu Agarwal, Adv. & Shri Akash Shukla, Adv. Date Of Hearing 06.05.2025 Date Of Pronouncement 04.08.2025 Order Per Manish Agarwal, Am : The Present Appeal Is Filed By The Revenue Against The Order Dated 12.08.2024 Passed By Ld. Commissioner Of Income Tax (A), National Faceless Appeal Centre (“Nfac”), Delhi [“Ld.Cit(A)”] In Appeal No. Cit(A), Delhi-8/10712/2016-17 U/S 250 Of The Income Tax Act, 1961 [“The Act”] Arising From The Order Dated 23.12.2016 Passed U/S 143(3) Of The Act Pertaining To Assessment Year 2014-15. 2. Brief Facts Of The Case Are That The Assessee Is A Private Limited Company & Is Running Hotels. The Return Of Income Was E-Filed On 29.11.2014, Declaring Total Income At Inr 7,21,35,196/-. The Case Was Selected For Scrutiny Under Cass By Way Of Issue Of Notice U/S 143(2) Of The Act On 01.09.2015. Thereafter, Various Notices Were Issued From Time To Time & Submissions Were Taken From The Assessee & Finally, The Assessment Was Completed At An Income Of Inr 30,38,83,394/- By Making Various Additions/Disallowances.

Section 143(2)Section 143(3)Section 14ASection 250Section 36(1)(vii)

assessee reversed the said provision and claimed deduction thereof. * Thus, the mandatory conditions for claiming write-off of bad-debts in terms of section 36(1)(vii) of the Act have been fulfilled. [(i) the provision for doubtful debt was debited and the corresponding debtor account has been credited, thereby ... instant case, we find that the assessee successfully demonstrate that both the conditions have been fulfilled for claiming bad debts as per section 36(1)(vii) of the Act. Ld. CIT(A) after considering these facts, has deleted the disallowance by observing as under:- D. Findings i) “The Assessing Officer

ACIT-2(3)(1), Mumbai vs. Tata Capital Limited (Successor to Tata Cleantech Capital Limited), Mumbai

In the result, appeal of the Revenue is dismissed

ITA 3456/MUM/2024[2016-17]Status: DisposedITAT Mumbai31 Jul 2025AY 2016-17

Bench: Shri Amit Shukla & Shri Girish Agrawalassessment Year: 2016-17

For Appellant: Shri Anish Thacker, CAFor Respondent: Shri Hemanshu Joshi, Sr. DR
Section 143(3)Section 147Section 148Section 36(1)(viii)Section 80Section 80I

seen that the assessee has claimed a deduction of 7,50,00,000/- under section 36(1)(viii). As per Explanation (g) of section 36(1)(vii) of the Income Tax Act, 1961, "infrastructure facility" means - (ii) an undertaking referred to in clause (iv) of sub-section (4) of section

Deputy Commissioner of Income Tax, Jhandewalan Extn vs. Indian Potash Limited, Chennai

In the result, the appeal filed by the Revenue is dismissed and appeal filed by the assessee is allowed

ITA 4578/DEL/2024[2018-19]Status: DisposedITAT Delhi23 Jul 2025AY 2018-19

Bench: Shri S. Rifaur Rahman & Shri Vimal Kumarindian Potash Limited, Vs. Dcit, Central Circle 1, 1St Floor, Seethakathi Business Centre, New Delhi. 684 – 690, Anna Salai Thousand Lights, Chennai – 600 006 (Tamil Nadu). (Pan : Aaaci0888H) Dcit, Central Circle 1, Vs. Indian Potash Limited, 1St Floor, Seethakathi Business Centre, New Delhi. 684 – 690, Anna Salai Thousand Lights, Chennai – 600 006 (Tamil Nadu). (Pan : Aaaci0888H) (Appellant) (Respondent) Assessee By : Shri Akshat Jain, Ca Shri Rajat Jain, Ca Revenue By : Shri Dayainder Singh Sidhu, Cit Dr Date Of Hearing : 05.06.2025 Date Of Order : 23.07.2025 O R D E R Per S.Rifaur Rahman: 1. These Cross Appeals Are Filed By The Assessee & Revenue Against The Order Of Ld. Commissioner Of Income-Tax (Appeals), Delhi – 23 [Hereinafter Referred To As ‘Ld. Cit (A)] Dated 10.07.2024 For Assessment Year 2018-19. 2. The Revenue Has Raised The Following Grounds Of Appeal :- “1. The Order Of Ld. Cit (A) Is Not Correct In Law & Facts. 2. Whether On The Facts & Circumstances Of The Case Ld. Cit (A) Is Justified In Deleting The Addition Of Rs.88,67,868/- On Account Of Disallowance Of Excess Depreciation Claimed On Pos Machine. 3. Whether On The Facts & Circumstances Of The Case Ld. Cit (A) Is Justified In Deleting The Addition Of Rs.70,55,840/- On Account Of Disallowance Of Excess Depreciation Claimed On Sap License. 4. Whether On The Facts & Circumstances Of The Case Ld. Cit (A) Is Justified In Deleting The Addition Of Rs.9,71,46,262/- On Account Of Disallowance Of Excess Bad Debt Claimed On Which The Company Is Not Eligible For Taking The Benefit Of Claiming Of Subsidy By The Government Of India For Violation Of Subsidy By The Government Of India For Violation Of Norms Set By The Ministry Of Chemical & Fertilizers.”

For Appellant: Shri Akshat Jain, CAFor Respondent: Shri Dayainder Singh Sidhu, CIT DR
Section 36(1)(vii)Section 36(2)

portion of same was not actually received by the assessee. Therefore, ld. CIT(A) allowed the claim by reference to the provisions of section 36(1)(vii) and 36(2) of the Income tax Act, 1961 (for short ‘the Act’). Further, the Ld. CIT(A) has sustained the balance addition

Indian Potash Limited, Chennai vs. Deputy Commissioner of Income Tax, Central Circle - 1, New Delhi

In the result, the appeal filed by the Revenue is dismissed and appeal filed by the assessee is allowed

ITA 4113/DEL/2024[2018-19]Status: DisposedITAT Delhi23 Jul 2025AY 2018-19

Bench: Shri S. Rifaur Rahman & Shri Vimal Kumarindian Potash Limited, Vs. Dcit, Central Circle 1, 1St Floor, Seethakathi Business Centre, New Delhi. 684 – 690, Anna Salai Thousand Lights, Chennai – 600 006 (Tamil Nadu). (Pan : Aaaci0888H) Dcit, Central Circle 1, Vs. Indian Potash Limited, 1St Floor, Seethakathi Business Centre, New Delhi. 684 – 690, Anna Salai Thousand Lights, Chennai – 600 006 (Tamil Nadu). (Pan : Aaaci0888H) (Appellant) (Respondent) Assessee By : Shri Akshat Jain, Ca Shri Rajat Jain, Ca Revenue By : Shri Dayainder Singh Sidhu, Cit Dr Date Of Hearing : 05.06.2025 Date Of Order : 23.07.2025 O R D E R Per S.Rifaur Rahman: 1. These Cross Appeals Are Filed By The Assessee & Revenue Against The Order Of Ld. Commissioner Of Income-Tax (Appeals), Delhi – 23 [Hereinafter Referred To As ‘Ld. Cit (A)] Dated 10.07.2024 For Assessment Year 2018-19. 2. The Revenue Has Raised The Following Grounds Of Appeal :- “1. The Order Of Ld. Cit (A) Is Not Correct In Law & Facts. 2. Whether On The Facts & Circumstances Of The Case Ld. Cit (A) Is Justified In Deleting The Addition Of Rs.88,67,868/- On Account Of Disallowance Of Excess Depreciation Claimed On Pos Machine. 3. Whether On The Facts & Circumstances Of The Case Ld. Cit (A) Is Justified In Deleting The Addition Of Rs.70,55,840/- On Account Of Disallowance Of Excess Depreciation Claimed On Sap License. 4. Whether On The Facts & Circumstances Of The Case Ld. Cit (A) Is Justified In Deleting The Addition Of Rs.9,71,46,262/- On Account Of Disallowance Of Excess Bad Debt Claimed On Which The Company Is Not Eligible For Taking The Benefit Of Claiming Of Subsidy By The Government Of India For Violation Of Subsidy By The Government Of India For Violation Of Norms Set By The Ministry Of Chemical & Fertilizers.”

For Appellant: Shri Akshat Jain, CAFor Respondent: Shri Dayainder Singh Sidhu, CIT DR
Section 36(1)(vii)Section 36(2)

portion of same was not actually received by the assessee. Therefore, ld. CIT(A) allowed the claim by reference to the provisions of section 36(1)(vii) and 36(2) of the Income tax Act, 1961 (for short ‘the Act’). Further, the Ld. CIT(A) has sustained the balance addition

Vinita Bajoria, Jaipur vs. Income-Tax Officer, Jaipur

In the result, the appeal of the assessee is allowed

ITA 370/JPR/2025[201617]Status: DisposedITAT Jaipur21 Jul 2025

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI, AM आयकर अपील सं./ITA No. 370/JP/2025 निर्धारण वर्ष / Assessment Year : 2016-17 Vinita Bajoria 1, Ganesh Colony Moti Doongri Road, Jaipur बनाम Income Tax Officer, Ward 5(2), Jaipur स्थायी लेखा सं. / जीआईआर सं./PAN/GIR No.: AEBPB4873M अपीलार्थी / Appellant प्रत्यर्थी / Respondent निर्धारिती की ओर से / Assessee by: Sh. Manoj Choudhary, CA राजस्व की ओर से / Revenue by : Sh. Gorav Avasthi, JCIT सुनवाई की तारीख / Date of Hear

For Appellant: Sh. Manoj Choudhary, CAFor Respondent: Sh. Gorav Avasthi, JCIT
Section 147Section 148Section 148A

case, the reopening was made on the observations made during the Revenue Audit on non-compliance by the assessee of certain conditions of section 36(1)(vii) read with section 36(2) of the Act and in the Zuari Estate case, the assessee has not included certain transaction of property

ACIT-CC-7(3), Mumbai vs. Macrotech Developers Private Limited, Mumbai

In the result, the sole ground of appeal raised by

ITA 1486/MUM/2025[2013-14]Status: DisposedITAT Mumbai21 Jul 2025AY 2013-14

Bench: Shri Pawan Singh & Shri Prabhash Shankar

Section 254(1)Section 36(1)(iii)Section 36(1)(vii)Section 36(2)Section 43B

36(1)(vii) of the act without considering the fact that the assessee has claimed the said amount as a bad debt under section 36(1)(vii) of the Income Tax Act. However, the conditions stipulated under section 36(2) of the Act were not fulfilled. Specifically, section 36 ... authorities carefully. We find that Id. AR of the assessee explained the fact correctly. The assessing officer disallowed the provisions of advances under section 36(1)(vii) by taking view that assessee does not fulfilled the addition of section 36(2). Moreover, the assessee has not actually written

Macrotech Developers Limited (Mdl), Mumbai vs. Deputy Commissioner of Income Tax Central Circle 7(3), Mumbai

In the result, the sole ground of appeal raised by

ITA 1272/MUM/2025[2013-14]Status: DisposedITAT Mumbai21 Jul 2025AY 2013-14

Bench: Shri Pawan Singh & Shri Prabhash Shankar(Physical Hearing) Macrotech Developers Limited (Mdl) Dcit, Central Range – 7(3), Room No. 655, 6Th Floor, 412, Floor-4, 17G Vardhaman Chamber, Vs Cawasji Patel Road, Horniman Circle, Aayakar Bhavan, Maharshi Fort, Mumbai – 400001. Karve Road, Mumbai-400020. [Pan No. Aaacl1490J] Appellant / Assessee Respondent / Revenue (Physical Hearing) Acit – Cc – 7(3), Mumbai Macrotech Developers Private Limited Room No. 655, 6Th Floor, Vs 412, Floor-4, 17G Vardhaman Chamber, Aayakar Bhavan, Maharshi Cawasji Patel Road, Horniman Circle, Fort, Karve Road, Mumbai-400020. Mumbai – 400020. [Pan No. Aaacl1490J] Appellant / Assessee Respondent / Revenue

Section 254(1)Section 36(1)(iii)Section 36(1)(vii)Section 36(2)Section 43B

36(1)(vii) of the act without considering the fact that the assessee has claimed the said amount as a bad debt under section 36(1)(vii) of the Income Tax Act. However, the conditions stipulated under section 36(2) of the Act were not fulfilled. Specifically, section 36 ... authorities carefully. We find that ld. AR of the assessee explained the fact correctly. The assessing officer disallowed the provisions of advances under section 36(1)(vii) by taking view that assessee does not fulfilled the addition of section 36(2). Moreover, the assessee has not actually written

Deputy Commissioner of Income Tax, Circle-1(3)(1), Mumbai vs. Tmf Holdings Limited, Mumbai

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

ITA 2983/MUM/2025[2017-18]Status: DisposedITAT Mumbai18 Jul 2025AY 2017-18

Bench: Shri Anikesh Banerjee & Smt. Renu Jauhrideputy Commissioner Of Vs Tmf Holdings Limited 14, 4Th Floor, Sir H C Dinshaw Income Tax, Circle 1(3)(1), Mumbai Building, 16, Horniman Circle, Fort, Room No.535, 5Th Floor, Aaykar Mumbai-400 001 Bhavan, M.K. Road, Mumbai- Pan: Aacct4644A 400 020 Appellant Respondent

For Appellant: Shri Rajan Vora a/w Shri Nikhil TiwariFor Respondent: Shri Ritesh Mishra, CIT DR
Section 115JSection 143(3)Section 144BSection 147Section 148Section 250Section 37(1)

processed under section 143(1) of the Act by accepting the returned loss. Audit objections were raised regarding non-fulfilment of conditions of section 36(1)(vii) read with section 36(2) of the Act basis which the proceedings under section 147 of the Act were initiated [on the other ... makes an expense allowable under the provisions of the Act. Further, the assessee being an NBFC, is covered under the provisions of section 36(1)(vii) and 36(1) (viia). It could have provided for the bad and doubtful debts and even could have written it off. However, instead

DCIT-2(3)(1), Mumbai vs. Indusind Bank Ltd., Mumbai

In the result, the Income Tax Appeal is

ITA 3675/MUM/2023[2018-19]Status: DisposedITAT Mumbai17 Jul 2025AY 2018-19

Bench: Ms Padmavathy S, Am & Shri Raj Kumar Chauhan, Jm

For Appellant: Shri Kalpexh Unadkat &For Respondent: Shri Satya Pal Kumar, CIT-DR
Section 143(3)Section 14ASection 250Section 35DSection 36(1)(via)Section 36(1)(viia)Section 43B

IN THE INCOME TAX APPELLATE TRIBUNAL “I” BENCH, MUMBAI BEFORE MS PADMAVATHY S, AM & SHRI RAJ KUMAR CHAUHAN, JM I.T.A

Indusind Bank Ltd, Mumbai vs. The DCIT-2(3)(1), Mumbai

In the result, the Income Tax Appeal is

ITA 1842/MUM/2023[2019-20]Status: DisposedITAT Mumbai17 Jul 2025AY 2019-20

Bench: Ms Padmavathy S, Am & Shri Raj Kumar Chauhan, Jm

Section 143(3)Section 14ASection 250Section 35DSection 36(1)(via)Section 36(1)(viia)Section 43B

IN THE INCOME TAX APPELLATE TRIBUNAL “I” BENCH, MUMBAI BEFORE MS PADMAVATHY S, AM & SHRI RAJ KUMAR CHAUHAN, JM I.T.A

DCIT., Circle-1(1), Hyderabad vs. Creamline Dairy Products Limited, Hyderabad

In the result, appeal ITA

ITA 1183/HYD/2024[2017-18]Status: DisposedITAT Hyderabad16 Jul 2025AY 2017-18

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

For Appellant: CA, K C Devdas And CA C Maheshwar ReddyFor Respondent: Sri Narender Kumar Naik, CIT-DR
Section 139(1)Section 142(1)Section 143(2)Section 143(3)Section 80J

IN THE INCOME TAX APPELLATE TRIBUNAL HYDERABAD “B” BENCH: HYDERABAD BEFORE SHRI VIJAY PAL RAO, VICE PRESIDENT AND SHRI MANJUNATHA

Creamline Dairy Products Limited, Hyderabad vs. DCIT., Circle-1(1), Hyderabad

In the result, appeal ITA

ITA 1157/HYD/2024[2018-19]Status: DisposedITAT Hyderabad16 Jul 2025AY 2018-19

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

For Appellant: CA, K C Devdas And CA C Maheshwar ReddyFor Respondent: Sri Narender Kumar Naik, CIT-DR
Section 139(1)Section 142(1)Section 143(2)Section 143(3)Section 80J

IN THE INCOME TAX APPELLATE TRIBUNAL HYDERABAD “B” BENCH: HYDERABAD BEFORE SHRI VIJAY PAL RAO, VICE PRESIDENT AND SHRI MANJUNATHA

Creamline Dairy Products Limited, Hyderabad vs. ACIT., Circle-1(2), Hyderabad

In the result, appeal ITA

ITA 1156/HYD/2024[2017-18]Status: DisposedITAT Hyderabad16 Jul 2025AY 2017-18

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

For Appellant: CA, K C Devdas And CA C Maheshwar ReddyFor Respondent: Sri Narender Kumar Naik, CIT-DR
Section 139(1)Section 142(1)Section 143(2)Section 143(3)Section 80J

IN THE INCOME TAX APPELLATE TRIBUNAL HYDERABAD “B” BENCH: HYDERABAD BEFORE SHRI VIJAY PAL RAO, VICE PRESIDENT AND SHRI MANJUNATHA

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

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

ITA 635/MUM/2025[2012-13]Status: DisposedITAT Mumbai16 Jul 2025AY 2012-13

Bench: the Metropolitan Magistrate Court, Bandra, Mumbai.

For Appellant: Shri Vimal PunmiyaFor Respondent: Shri Ritesh Misra, CIT DR
Section 138Section 143(3)Section 144BSection 250Section 254Section 36Section 36(1)(vii)

upheld the alleged addition by an order dated 24/09/2021 on the ground that the said company had claimed deduction under section 36(1)(vii) of the Act amount to Rs.43,61,237/- which was disallowed and added back with the total income of the assesse. The Ld. AR argued narrated ... issue in the present appeal relates to the disallowance of the assessee's claim of bad debts amounting to Rs.43,61,237/- under section 36(1)(vii) of the Act, which was upheld by the revenue authorities on the ground that the assessee had merely made a provision for doubtful

M/S Gujarat Guardian Ltd., New Delhi vs. DCIT, New Delhi

ITA 2539/DEL/2017[2005-06]Status: DisposedITAT Delhi16 Jul 2025AY 2005-06

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

debt become actually shown as bad, the assessee is not entitled for the deduction of the bad debt as per the provisions of section 36(1)(vii) of the Act. 18. Counsel for the assessee argued that the assessee has duly written off these debts, which are in the nature

Gujarat Guardian Ltd., New Delhi vs. DCIT, New Delhi

ITA 159/DEL/2010[2003-04]Status: DisposedITAT Delhi16 Jul 2025AY 2003-04

Bench: Shri Prakash Chand Yadav & Shri Brajesh Kumar Singh

Section 92C

debt become actually shown as bad, the assessee is not entitled for the deduction of the bad debt as per the provisions of section 36(1)(vii) of the Act. 18. Counsel for the assessee argued that the assessee has duly written off these debts, which are in the nature

Deputy Commissioner of Income Tax, Circle-6(1)(1), Bangalore vs. Santosh Shivaji Lad, Bangalore

In the result, the appeal of the Revenue is hereby dismissed

ITA 1522/BANG/2024[2013-14]Status: DisposedITAT Bangalore14 Jul 2025AY 2013-14

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year: 2013-14

For Appellant: Shri V Srinivasan, AdvocateFor Respondent: Shri Murali Mohan M, CIT (DR)
Section 271(1)(c)Section 274Section 36(1)(vii)Section 36(2)Section 57

charged any interest on these advances in any financial year, indicating that the assessee did not comply with the provisions of section 36(1)(vii) read with section 36(2) of the Act, and thus, could not be claimed as bad debts. 5.1 Similarly, the AO observed that the assessee

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

In the result, the appeal is allowed for statistical purposes

ITA 2033/AHD/2017[2012-13]Status: DisposedITAT Ahmedabad08 Jul 2025AY 2012-13

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

For Appellant: Shri Bandish Soparkar, A.RFor Respondent: Shri Alpesh Parmar, CIT DR &
Section 115JSection 14ASection 50

claim was disallowed by the AO and upheld by the CIT(A) on the grounds of insufficient evidence and nonfulfilment of conditions under Section 36(1)(vii) for bad debt deduction. 56. During the course of hearing before us the AR stated that it is absolutely wrong on part ... orders of lower authorities. 58. We have considered the contentions of the parties. The CIT(A) concluded that the conditions laid down under Section 36(1)(vii) read with Section 36(2) were not fulfilled as details of the parties associated with the debts were not furnished, the assessee failed