9911796707
TMI Blog2013 (8) TMI 77X X X X Extracts X X X X X X X X Extracts X X X X ..... oner's objection nor Revenue contends that the belief of the Assessing Officer that income chargeable to tax has escaped assessment, is based on any material outside of the record - full facts were there before the Assessing Officer in the form of declarations made in the returns filed as well as through correspondence during the course of scrutiny assessment. This therefore, is not a case whe ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... respondent supplied reasons recorded by him for issuing such notice. Such reasons read as under : "It is noticed that the assessee had claimed bad debts of Rs. 90,879/- in its profit and loss accounts. On verification of computation of income it was noticed that the assessee had claimed bad debts of Rs. 9,42,126/- and reduced its taxable profit. Since, the amount of Rs. 9,42,126/- was not p ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ff) had not passed through the books of account, same is therefore, not allowable as expenditure. In short, the Assessing Officer's objection was that such sum claimed did not satisfy requirement of section 36(1)(vii) of the Act. 6. Having heard learned counsel for the parties, we recall that impugned notice has been issued beyond a period of four years from the end of relevant assessment year. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 9 had made following statement in support of the claim for deduction : "3. The company makes a provision for doubtful debts, were recovery of outstanding debt is doubtful. The provision so made for doubtful debts is disallowed in return of income. The outstanding debt was scrutinised and debt which was non-recoverable was only actually written off to customer's account by crediting to custo ..... X X X X Extracts X X X X X X X X Extracts X X X X
|
