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ITAT allowed appellant's appeal regarding disallowance of advance written-off as bad debt. Tribunal held that even if advance write-off was not allowable as bad debt under relevant provisions, it qualified as allowable business loss under Section 37(1) or Section 28(1) of the Act. The advance was made for business expediency in ordinary course of business and constituted genuine transaction, not sham or accommodation entry. Assessing Officer failed to establish cogent reasons for disallowance despite burden being on revenue authority. Tribunal also allowed deduction of prior period expenses including insurance premium and service charges, following precedent where revenue could not disprove crystallization of liability during relevant assessment year. Both grounds of appeal were allowed in favor of appellant.
ITAT allowed appellant's appeal regarding disallowance of advance written-off as bad debt. Tribunal held that even if advance write-off was not allowable as bad debt under relevant provisions, it qualified as allowable business loss under Section 37(1) or Section 28(1) of the Act. The advance was made for business expediency in ordinary course of business and constituted genuine transaction, not sham or accommodation entry. Assessing Officer failed to establish cogent reasons for disallowance despite burden being on revenue authority. Tribunal also allowed deduction of prior period expenses including insurance premium and service charges, following precedent where revenue could not disprove crystallization of liability during relevant assessment year. Both grounds of appeal were allowed in favor of appellant.
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