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TMI Blog2019 (1) TMI 2017X X X X Extracts X X X X X X X X Extracts X X X X ..... mar, Sr. Standing Counsel. For the Respondent : Mr. N.V. Balaji. COMMON JUDGMENT Delivered by Dr. Anita Sumanth, J. These Tax Case (Appeals) have been filed by the Revenue challenging an order of the Income Tax Appellate Tribunal dated 14.09.2007 relating to Assessment Years 2002-03 and 2003-04. 2. Two issues arise in these appeals and by order dated 30.11.2009, the following substantial que ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ed in favour of the assessee and against the Revenue. 5. As regards the second substantial question of law, the provisions of section 36(1)(vii) of the Income Tax Act, 1961 provide for allowance of an amount representing bad debt or part thereof, which is written off as irrecoverable in the accounts of the assessee for the previous year. 6. In the present case, the admitted fact is that the asse ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... claim of the assessee. 8. We find, as a matter of fact, that the Tribunal has taken note of the position that the Memorandum and Articles of Association permitted the assessee to carry on the business of money lending and the transactions in question have been held to be in the realm of business activity. 9. There is no dispute raised before us on this factual position. In the light of the same, ..... X X X X Extracts X X X X X X X X Extracts X X X X
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