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The HC upheld the ITAT's decision allowing write-offs of small advances (totaling Rs.7,66,713) under section 36(1)(vii). The Court found that the DRP incorrectly characterized the claim as unsupported by evidence, noting the respondent-assessee had provided details of advances to over 50 parties that were either unrecoverable or without corresponding services. Given the assessee's total declared income exceeding Rs.30 crore, these relatively minor write-offs were deemed reasonable. However, regarding the "Site Transfer Income" deduction under section 10B for the Goa and Ambarnath units, the HC remanded the matter to the ITAT for a reasoned determination, finding the Tribunal had merely stated its conclusion without providing adequate legal reasoning.
The HC upheld the ITAT's decision allowing write-offs of small advances (totaling Rs.7,66,713) under section 36(1)(vii). The Court found that the DRP incorrectly characterized the claim as unsupported by evidence, noting the respondent-assessee had provided details of advances to over 50 parties that were either unrecoverable or without corresponding services. Given the assessee's total declared income exceeding Rs.30 crore, these relatively minor write-offs were deemed reasonable. However, regarding the "Site Transfer Income" deduction under section 10B for the Goa and Ambarnath units, the HC remanded the matter to the ITAT for a reasoned determination, finding the Tribunal had merely stated its conclusion without providing adequate legal reasoning.
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