Trademark depreciation and section 14A adjustments: ITAT applies consistency, independent book-profit computation, and no disallowance without exempt ...
Rebuttable search presumptions and corroboration standards shaped deletion of unsubstantiated additions, while rental income and limited profit estima...
Bad debt deduction depends on an effective write-off, not on a mere provision for bad and doubtful debts after the Explanation inserted from 1-4-1989. Where the assessee debited the amount to the profit and loss account and made corresponding entries treating the debt as irrecoverable, the write-off requirement was substantially satisfied, even though the individual debtor's ledger was not formally closed because recovery litigation was pending. The pendency of recovery proceedings explained the absence of ledger closure and did not convert the claim into a bare provision. Any later recovery would remain taxable in the year of recovery. On that basis, the deduction was allowed and the disallowance was set aside.
Bad debt deduction depends on an effective write-off, not on a mere provision for bad and doubtful debts after the Explanation inserted from 1-4-1989. Where the assessee debited the amount to the profit and loss account and made corresponding entries treating the debt as irrecoverable, the write-off requirement was substantially satisfied, even though the individual debtor's ledger was not formally closed because recovery litigation was pending. The pendency of recovery proceedings explained the absence of ledger closure and did not convert the claim into a bare provision. Any later recovery would remain taxable in the year of recovery. On that basis, the deduction was allowed and the disallowance was set aside.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4816 
Join Channel 
