Supervisory permanent establishment requires project-wise duration and qualifying construction nexus; offshore supplies and salary reimbursements rema...
Transfer-pricing comparability permits fresh objections and filters where software service comparables are functionally unsuitable for arm's-length pr...
Territorial rendering requirement excludes China-based management and consultancy services from fees for technical services under the India-China DTAA...
Assessee wrote off provision for bad and doubtful debts by debiting profit and loss account and reducing corresponding amount from loans and advances to debtors in balance sheet. CIT(A) erred in holding assessee failed to demonstrate amounts were written off as irrecoverable. Records show amounts were written off by deducting them in P&L account and set off properly recorded in balance sheet. As per Supreme Court ruling in Vijaya Bank case, to claim deduction u/s 36(1)(vii), it's not necessary to close individual debtor accounts; writing off by debiting P&L and reducing corresponding asset side entry suffices. Hence, assessee is eligible for deduction and appeal allowed.
Assessee wrote off provision for bad and doubtful debts by debiting profit and loss account and reducing corresponding amount from loans and advances to debtors in balance sheet. CIT(A) erred in holding assessee failed to demonstrate amounts were written off as irrecoverable. Records show amounts were written off by deducting them in P&L account and set off properly recorded in balance sheet. As per Supreme Court ruling in Vijaya Bank case, to claim deduction u/s 36(1)(vii), it's not necessary to close individual debtor accounts; writing off by debiting P&L and reducing corresponding asset side entry suffices. Hence, assessee is eligible for deduction and appeal allowed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4883 
