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TMI Blog2012 (7) TMI 790X X X X Extracts X X X X X X X X Extracts X X X X ..... mount had been advanced as loan - assessee has written off this amount as per Section 36(1)(vii) in the books of account - disallowance rightly deleted - In favor of assessee - IT(SS)A No. 232/Ahd/2012 - - - Dated:- 5-6-2012 - Shri D.K. Tyagi, Judicial Member And Shri T.R. Meena, JJ. By Appellant : Ms. Surabhi Sharma, Sr. D.R O R D E R PER : T.R.Meena, Accountant Member This i ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 3. The assessee was in appeal before CIT(A)-I, Ahmedabad, who has allowed the appeal in favour of the assessee by observing in paragraph no. 6 is as under:- 6. After going through rival submissions, it is seen that the appellant is engaged in the business of finance activities and its profit and loss account shows interest income received of Rs.23,50,029. P L account is enclosed as Annexure-1 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Rs.7,72,33,000. As against this advances were made of Rs.4,66,30,875 during the year under consideration. As per section 36(1)(vii) deduction of bad debt written off as irrecoverable in the accounts of the assessee for the previous year can be allowed as deduction subject to the provisions of section 36(2). Section 36(2)(i) states : no such deduction shall be allowed unless such debt or part the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... llant. Therefore, relying upon Hon ble Supreme Court decision in the case of TRF Ltd. Vs. CIT 323 ITR 390 also in view of the factual position discussed above the Assessing Officer is directed to delete the addition of Rs.19,00,000/-. 4. Now the Revenue is before us. Ld. D.R. vehemently opposed the deletion made by the CIT(A) and argued for confirmation of addition made by the A.O. whereas from ..... X X X X Extracts X X X X X X X X Extracts X X X X
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