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    <title>2025 (6) TMI 1209 - ITAT AHMEDABAD</title>
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    <description>ITAT Ahmedabad allowed assessee&#039;s appeal regarding bad debts disallowance. Out of Rs. 3.90 crores disallowed, Rs. 1.95 crores relating to M/s Pujan Impex was allowed under section 36(2) as proper bad debt, while remaining Rs. 2 crores was allowed under section 37(1) as business advances written off. Addition under section 41(1) for cessation of liability was deleted as amount waived by Suzlon represented debit balance, not credit liability. Legal and professional fees related to property transaction were allowed as revenue neutral exercise since property profit was taxed in preceding year. Disallowance under section 40(a)(ia) for late TDS deposit was deleted following Supreme Court precedent in Calcutta Exports case.</description>
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      <link>https://www.taxtmi.com/caselaws?id=773096</link>
      <description>ITAT Ahmedabad allowed assessee&#039;s appeal regarding bad debts disallowance. Out of Rs. 3.90 crores disallowed, Rs. 1.95 crores relating to M/s Pujan Impex was allowed under section 36(2) as proper bad debt, while remaining Rs. 2 crores was allowed under section 37(1) as business advances written off. Addition under section 41(1) for cessation of liability was deleted as amount waived by Suzlon represented debit balance, not credit liability. Legal and professional fees related to property transaction were allowed as revenue neutral exercise since property profit was taxed in preceding year. Disallowance under section 40(a)(ia) for late TDS deposit was deleted following Supreme Court precedent in Calcutta Exports case.</description>
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