Condonation of Delay: directoral disputes and pending company proceedings can constitute reasonable cause, allowing a belated return to be treated as ...
Revisionary jurisdiction under section 263 upheld; faceless assessments subject to revision when AO fails requisite enquiries, remitted for fresh asse...
Limited scope of processing under section 143(1): enhancement without show cause is unsustainable; remand for residency, taxation and TDS verification...
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.
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