Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
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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.
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