Bad debt deduction denied where write-off occurred after assessment and the statutory condition for allowance was not met.

Deduction for bad debt was unavailable where the assessee wrote off the debt only after the assessment for the relevant year had been completed, because the statutory condition under section 36(2) was not satisfied. The revised return was filed after the assessment order, and on the facts found by the Tribunal there was no basis to disturb the conclusion that the claim failed. The first question was answered in the affirmative and against the assessee.

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Issues: Whether the assessee was entitled to claim deduction for bad debt when the write-off was made only after the assessment order for the relevant year had been passed, and whether the Tribunal was justified in disallowing the claim under section 36(2) of the Income-tax Act, 1961.

Analysis: The assessee's revised return was filed after the assessment order for the relevant year. The requirement under section 36(2) was not satisfied because the debt had not been written off before the assessment was completed. On the facts found by the Tribunal, there was no basis to interfere with the finding that the statutory condition for allowance of bad debt was not met.

Conclusion: The first question was answered in the affirmative and against the assessee.

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