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ITAT upheld CIT(A)'s deletion of an addition where the assessee wrote off sundry advances to its subsidiary, concluding the advances and share capital were integrally connected to the assessee's hospitality business transferred to the subsidiary. The Tribunal found the write-off incurred in the relevant assessment year, attributable to business exigencies (pandemic-related slowdown), and therefore deductible under s.37(1) as a business loss and alternatively under s.36(1)(vii) as bad debt (part of which had been offered as income). The AO's contention that the advances lacked nexus with business or were merely capital liabilities was rejected; the ITAT found no infirmity in CIT(A)'s order.
ITAT upheld CIT(A)'s deletion of an addition where the assessee wrote off sundry advances to its subsidiary, concluding the advances and share capital were integrally connected to the assessee's hospitality business transferred to the subsidiary. The Tribunal found the write-off incurred in the relevant assessment year, attributable to business exigencies (pandemic-related slowdown), and therefore deductible under s.37(1) as a business loss and alternatively under s.36(1)(vii) as bad debt (part of which had been offered as income). The AO's contention that the advances lacked nexus with business or were merely capital liabilities was rejected; the ITAT found no infirmity in CIT(A)'s order.
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