TaxTMI 
TaxTMI 
2013 (5) TMI 475
X X X X Extracts X X X X
X X X X Extracts X X X X
....cate ORDER The present appeal under Section 260-A of the Income Tax Act, 1961 (for short 'the Act') is directed against an order dated 26.04.2011 passed by the Income Tax Appellate Tribunal (for short 'the Tribunal') in respect of the assessment year 2005- 06. The assessee has claimed following substantial questions of law: "i) Whether on the facts and circumstances of the case, Tribunal ord....
X X X X Extracts X X X X
X X X X Extracts X X X X
.... was incorporated on 07.03.1976 with an object to develop and promote the electronics, telecommunication and I.T. etc. in the State of Punjab. Subsequently, three subsidiary companies were incorporated. The assessee has advanced loans to the said subsidiary companies, which were written off as bad debts. The assessee claimed the amount written off as a revenue expense which the Assessing Officer t....
X X X X Extracts X X X X
X X X X Extracts X X X X
....As far as judicial pronouncement relied upon by the counsel are concerned there are entirely distinguishable to the facts of the instant case." In further appeal at the instance of the assessee, the Tribunal returned a finding that the amounts advanced by the assessee have been written off after the said companies have been closed and the employees retrenched. The amounts so advanced are clearly ....
X X X X Extracts X X X X
X X X X Extracts X X X X
.... issue and return a finding whether the amount advanced is in the course of business and the same being irrecoverable have been written off by the assessee, is to be considered as revenue expenditure under Section 37(1) of the Act. We have heard learned counsel for the parties and find no merit in the present appeal. Since the appellant has advanced loan to its subsidiary companies, the same has ....