https://www.taxtmi.com/caselaws?id=467294 The tribunal held that the Rs. 251.30 crore loss from assignment of intra-group receivables and payables was a notional, capital/investment type loss unsupported by contemporaneous recovery efforts, pre assignment valuation or sale/escrow documentation, and therefore not allowable as a bad debt under section 36(1)(vii) nor as a business loss under section 28(i). The disallowance of excess interest of Rs. 158.12 crore on intercorporate deposits under section 36(1)(iii) was upheld for lack of commercial expediency evidence. Interest on overseas investment (Rs. 171.57 crore) and TDS credit (Rs. 2.29 crore) were remanded to the assessing officer for verification; personal hearing ground was dismissed. en-us Wed, 11 Sep 2024 00:00:00 +0530 Thu, 12 Mar 2026 17:01:34 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=467294 The tribunal held that the Rs. 251.30 crore loss from assignment of intra-group receivables and payables was a notional, capital/investment type loss unsupported by contemporaneous recovery efforts, pre assignment valuation or sale/escrow documentation, and therefore not allowable as a bad debt under section 36(1)(vii) nor as a business loss under section 28(i). The disallowance of excess interest of Rs. 158.12 crore on intercorporate deposits under section 36(1)(iii) was upheld for lack of commercial expediency evidence. Interest on overseas investment (Rs. 171.57 crore) and TDS credit (Rs. 2.29 crore) were remanded to the assessing officer for verification; personal hearing ground was dismissed. Case-Laws Income Tax Wed, 11 Sep 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=467294