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TMI Blog2022 (3) TMI 567X X X X Extracts X X X X X X X X Extracts X X X X ..... is to be computed in accordance with the commercial principles. Before us, Revenue has not placed any contrary binding decision in its support nor has pointed to any fallacy in the findings of CIT(A). In such a situation, we find no reason to interfere with the order of CIT(A). Thus the grounds of the Revenue are dismissed. X X X X Extracts X X X X X X X X Extracts X X X X ..... oubtful debts are not allowable. (iii) The appellant craves leave to add, to alter or amend any ground of appeal raised above at the time of hearing." 4. Before us, at the outset, Learned DR submitted that though Revenue has raised various grounds but the sole controversy is with respect to the allowing of Provision for doubtful debts as application of income by Learned CIT(A). 5. During the course of assessment proceedings, AO on perusing the Income and Expenditure Account noticed that an amount of ₹ 3,32,58,322/- was claimed as application of income on account of "Provision for doubtful debts". AO was of the view that the same was not allowable as application as it is not an ascertained liability and had not been applied durin ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 345 ITR 362. 7. CIT(A) after considering the submissions of the assessee decided the issue in favour of the assessee by observing as under: "5.2 Grounds of appeal no.2 challenges the disallowance of ₹ 3,32,58,322/- as application of income on account of provisions for doubtful debts. 5.2.1 The Assessing Officer has denied the said amount as application since its provisions for doubtful debts is not ascertained liability and has not been applied. The appellant has submitted that the assessee is a trust carrying out charitable activities and income has to be computed on commercial principles. It has further been submitted that the provisions of its bad debts ascertained and quantified. As regards, the judgments relied upon it has ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ative in favour of the assessee and against the Revenue : "Whether the Tribunal was right in law in holding that the provision for doubtful debts must be deducted from the income of the trust on commercial principles, for the purposes of section 11(1)(a) of the Act ?" " 5.2.3 As has been observed by the Hon'ble High Court in the case under consideration also there is nothing on record to show that the provisions was not made bonafide. On the contrary the appellant has submitted details of show that the provisions of it's towards which are ascertained and quantified. It is also apparent that the provision was made in furtherance of the objectives of the trust. In view of the discussion above relying on the judgme ..... X X X X Extracts X X X X X X X X Extracts X X X X
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