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Court Rules on Tax Deductions: Profit Apportionment Not Equivalent to Bad Debt Provision Under Income Tax Act Sections 36(1)(viia) & (viii.
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....Deduction u/s 36(1)(viia) or u/s 36(1)(viii) - creation of special reserve fund - the assessee has tried to equate the apportionment of profit against an expenditure for provision for bad and doubtful debts which in our view is not possible.....