2015 (10) TMI 1420

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....Per Joginder Singh (Judicial Member) The assessee is aggrieved by the impugned order dated 20/02/2012, of the ld. First Appellate Authority, Mumbai. 2. During hearing of this appeal, the ld. counsel for the assessee, Shri M.C. Naniwadekar, did not press ground no.2 with respect to appropriated deduction u/s 10A of the Act, thus, this ground is dismissed as not pressed. 2.1. The only groun....

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.... in brief, are that the assessee is engaged in the business of developing still graphic animation images, claimed Rs. 61,91,962/- as bad debt written off. The ld. Assessing Officer denied the claim on the ground that the debts, which were written off was only of parent company as the assessee is 100% subsidiary of the debtor and thus, such claim was not a bona-fide commercial decision. On appeal, ....

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....n 124 (Del.)  , Suresh Gaggal vs ITO (2009) 180 Taxman 90 (HP) , Lawlys Enterprises ltd. vs CIT 314 ITR 297 (Pat.), DIT vs Owan International Bank (2009) 184 taxman 314 (Bom.)  The fact of amendment to section 36(1)(vii) read with section 36(2) is only that now for claiming deduction u/s 36(1)(vii) mere writing off debt or part thereof as irrecoverable is a substantial compliance. Our vi....