Share investment write-off denied where shares were held as investments, not stock-in-trade, and loss arose only on sale.

Share investments held as capital investments, and not as stock-in-trade, could not be written off as bad debts merely because their value had fallen. On the admitted facts, the holdings remained with the assessee, no specific provision of the Income-tax Act supported the claimed write-off, and any loss would arise only on an actual sale at a lower price. The Tribunal therefore treated the proposed deduction as legally unsustainable, and the claim for write-off was rejected.

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Issues: Whether the assessee-corporation could claim a deduction by writing off share investments as a bad investment, treating them like bad debts, when the shares were held as investments and not as stock-in-trade.

Analysis: The Tribunal found that the corporation had invested in shares, had not treated them as stock-in-trade, and the holdings continued to remain with the assessee. On those facts, a write-off on the footing of bad debts was not legally sustainable. The Court further held that no specific provision of the Income-tax Act supported the claimed write-off on the admitted factual matrix, and that any possible loss would arise only upon actual sale of the shares at a lower value.

Conclusion: The claim for write-off was rejected and no question of law arose in the appeal.

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