TaxTMI 
TaxTMI 
2019 (11) TMI 976
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....d confirmed by the Ld. CIT(A) on account of bad debts written off. 3. The assessee in the present case is a company which is engaged in the business of providing corporate education and management training to graduates. The return of income for the year under consideration was filed by it on 31.10.2007 declaring a total income at Nil. In the P & L A/c filed along with the said return, a sum of Rs. 53,15,574/- was debited by the assessee on account of bad debts written off. During the course of assessment proceedings, the relevant details were furnished by the assessee in writing to show that course fees receivable from 16 students had remained unpaid and the same was written off as irrecoverable in the books of account for the year under....
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....that the details of bad debts in the form of unpaid fees (out of total fees of Rs. 3,75,000/- per student already credited to the P & L Account of Rs. 53,75,574/- had been furnished to the AO during the assessment proceedings. It was stated that the claim was made u/s. 36(i)(vii) of the Act and cited certain case laws to state that the only conditions to be fulfilled to claim the deduction were that the bad debts should be written off in the relevant previous year and the relevant income should have been offered in some previous year. The submissions were forwarded by the then CIT(A)-XVI, Kolkata on 18.04.2014 to the AO for verification. The ITO, Ward 2(3), Kolkata finally reported vide letter dated 08.04.2016 that the appellant was granted....
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....y the authorities below. He also contended that the relevant details to support and substantiate its claim for the bad debts written off were not fully furnished by the assessee either before the AO or before the Ld. CIT(A). 7. We have considered the rival submissions and also perused the relevant material available on record. It is observed that the relevant details in respect of its claim for bad debts written off were furnished by the assessee during the course of assessment proceedings before the AO and only on perusal of the same, it was found by the AO that almost the entire course fees receivable by the assessee from 16 students was written off by the assessee as bad debts. As rightly contended by the learned counsel for the asses....
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....ring the course of appellate proceedings before the Ld. CIT(A), it was submitted by the assessee that the expenses in question were incurred on portal development and the said expenses incurred continuously in the earlier years as well as in the subsequent year were written off partly in the relevant years including the year under consideration. It was also pointed out by the assessee that a similar deduction on account of miscellaneous expenses written off was claimed by the assessee in AY 2003-04 at Rs. 55,55,097/- being 1/3rd of the total portal development expenses incurred by them and the disallowance of the same made by the AO was deleted by the Ld. CIT(A). The Ld. CIT(A) did not find merit in these submissions made on behalf of the a....
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.... treated as allowed for statistical purpose. 12. As regards ground No. 3, it is observed that the expenditure of Rs. 30,000/- claimed by the assessee under the head "membership fees and subscription" was disallowed by the authorities below by treating the same as capital expenditure on the ground that the expenditure in question was claimed by the assessee on account of entrance fees paid to Oberai Hotel. 13. At the time of hearing before us, the learned counsel for the assessee has submitted that it was annual fees paid by the assessee to Hotel Oberai and not an entrance fees. He however has not brought on record any documentary evidence to show that the amount in question represents annual fees paid to Hotel Oberai and not the entra....