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    <description>Loss arising from transfer of non-performing assets to an asset reconstruction company crystallises when the loan portfolio is transferred for cash and security receipts and the loan accounts are closed. RBI norms require derecognition of transferred financial assets and write-off of any shortfall against net book value. Where previously deducted bad-debt provisions have already been reversed in tax computation, allowing the transfer loss does not create a double deduction. The loss is characterised as a revenue trading loss incidental to banking business, rather than a contingent or notional loss, and is allowable as a business loss under Section 28 of the Income-tax Act, 1961.</description>
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