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TMI Blog2013 (12) TMI 370X X X X Extracts X X X X X X X X Extracts X X X X ..... e Tax Appellate Tribunal, Cochin Bench in I.T.A.No.547/Coch/2010. The issue relates to the assessment year 2007-2008. 2. The assessee had filed a return on 16/10/2007. The case was selected for scrutiny which was completed under Section 143(3) of the Income Tax Act on 07/12/2009 disallowing a sum of Rs.5,70,13,359/- being bad debts written off u/s 36(1)(vii) and disallowance under Section 14A for ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... appellate authority, who had only partially confirmed the disallowance of claim of bad debts u/s 14A of the Act. 3. In regard to the first issue relating to disallowance of claim of bad debts amounting to Rs.5,70,13,359/- it was disallowed by the Asssessing Officer mainly on the ground that the assessee failed to comply with provisions of Section 36(2)(v) of the Act. In fact, the assessee wrote o ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... to the provision account then the said account will show a debit balance of Rs.5.7 crores which has to be closed by transferring it to the profit and loss account. It is found that the net effect would be that both methodologies would give the same result. 4. The next issue is with reference to reduction of excess provision written back. The Tribunal found that there was no discussion about the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... thods suggested by the Assessing Officer and the assessee is taken into account, the effect will be the same. 6. Though the learned counsel for the appellant tried to impress upon us that a substantial question of law arises for consideration in the appeal, we do not think so. The question raised is whether on the facts and circumstances of the case, and in the light of Section 36(1)(vii) read wi ..... X X X X Extracts X X X X X X X X Extracts X X X X
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