https://www.taxtmi.com/caselaws?id=257463 Deduction for bad debts requires both a debit to profit and loss and a credit that obliterates the asset; a writeoff occurs only in the year the debtor's account is squared off, so deduction under section 36(1)(vii) is allowable in the year the asset is extinguished. Payments to nonresidents claimed as agency commission do not attract the explanation to the withholding provision where there is no accrual of income in India; absent Indian accrual, there is no obligation to deduct tax at source and disallowance under section 40(a)(i) cannot be sustained. Both issues decided in favour of the assessee. en-us Fri, 13 Feb 2015 00:00:00 +0530 Thu, 05 Feb 2026 16:27:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=257463 Deduction for bad debts requires both a debit to profit and loss and a credit that obliterates the asset; a writeoff occurs only in the year the debtor's account is squared off, so deduction under section 36(1)(vii) is allowable in the year the asset is extinguished. Payments to nonresidents claimed as agency commission do not attract the explanation to the withholding provision where there is no accrual of income in India; absent Indian accrual, there is no obligation to deduct tax at source and disallowance under section 40(a)(i) cannot be sustained. Both issues decided in favour of the assessee. Case-Laws Income Tax Fri, 13 Feb 2015 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=257463