Tribunal grants appellant partial relief for assessment years 2006-07 and 2007-08.

The Tribunal partially allowed the appellant's appeals for the assessment years 2006-07 and 2007-08. Some issues were remanded for further verification and denovo adjudication, while others were allowed based on settled legal precedents and consistent accounting practices. The appellant's challenges regarding adjustment for CENVAT, club expenditure, bad debts, membership fees, irrecoverable debts, and unreconciled transactions were addressed, with certain grounds dismissed and others allowed in favor of the appellant.

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Issues involved:
1. Adjustment for proportionate element of CENVAT under section 145A
2. Disallowance of club expenditure
3. Disallowance of bad and doubtful debt written off
4. Disallowance of subscription/membership fees paid to clubs
5. Disallowance of debts written off as irrecoverable
6. Alleged unreconciled transactions

Issue 1: Adjustment for proportionate element of CENVAT under section 145A
The appellant appealed against the addition to total income due to the adjustment for the proportionate element of CENVAT under section 145A. The appellant decided not to press this ground, and it was dismissed accordingly as "not pressed."

Issue 2: Disallowance of club expenditure
The appellant contested the disallowance of club expenditure, citing a previous Tribunal decision in their favor. The Tribunal found that the issue was settled in favor of the appellant based on previous judgments and allowed the ground raised by the appellant.

Issue 3: Disallowance of bad and doubtful debt written off
The appellant challenged the disallowance of bad and doubtful debt written off, citing a Supreme Court judgment and consistent accounting practices. The Tribunal remanded the issue to the Assessing Officer for verification based on a subsequent Tribunal decision and allowed the ground raised by the appellant for statistical purposes.

Issue 4: Disallowance of subscription/membership fees paid to clubs
The appellant disputed the disallowance of subscription/membership fees paid to clubs. The Tribunal noted that this issue was common to a previous assessment year where the ground was allowed in favor of the appellant. Consequently, the Tribunal set aside the impugned order and allowed the ground raised by the appellant.

Issue 5: Disallowance of debts written off as irrecoverable
The appellant contested the disallowance of debts written off as irrecoverable. The Tribunal found this issue common to a previous assessment year and remanded it to the Assessing Officer for denovo adjudication, allowing the ground raised by the appellant for statistical purposes.

Issue 6: Alleged unreconciled transactions
The appellant challenged the disallowance on account of alleged unreconciled transactions. The Tribunal directed the issue to be remanded to the Assessing Officer for providing specific information to enable the reconciliation. The ground was allowed for statistical purposes.

In conclusion, the Tribunal partially allowed the appellant's appeals for the assessment years 2006-07 and 2007-08 on various grounds, remanding some issues for further verification and denovo adjudication while allowing others based on settled legal precedents and consistent accounting practices.

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