2017 (3) TMI 1551

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X

..... he mischief under the explanation to Section 37 (1) as it was the interest paid for late repayment of advance to M/s IFCI Ltd, even as far as the amount written off, i.e., ₹ 70,44,023/- is concerned. The Court notes that the sole rationale for disallowance by the AO was that the assessee had stopped its business. The assessee had claimed the said amount as the value of old stock written off. .....

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X

..... /s IFCI Ltd. ignoring the fact that the said expenditure is not allowable as deduction as per the explanation to section 37 (1) of the Income Tax Act, 1961? (ii) Whether the ITAT erred in deleting the addition of ₹ 70,44,023/- made by the Assessing Officer on account of amounts written off ignoring the fact that there was no business during the year under consideration and these amounts .....

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X

..... w is concerned: - Whether the ITAT erred in deleting the addition of ₹ 22,90,00,000/- made by the Assessing Officer on account of amount transferred to capital reserve ignoring the fact that the said amount was a revenue receipt in the hands of the assessee and therefore the provision of Section 41 (1) of the Act was applicable? Issue notice of appeal to the respondent/assessee, retu .....

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X