2020 (11) TMI 458
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.....2020, neither the assessee nor its authorized representative appeared before the Tribunal on the above date. As there is non-compliance by the assessee, we are proceeding to dispose off this appeal, after examining the documents available on record and after hearing the Ld. Departmental Representative (DR). 2. The grounds of appeal filed by the assessee read as under : 1.1. The learned CIT (A) erred in disallowing a sum of Rs. 8,21,987/- merely on the basis that corresponding income has not been offered to tax in any earlier year. 1.2 The learned CIT(A) erred in not granting deduction under Section 28 of the Act and without considering the explanations of the Appellant. 1.3. The learned CIT (A) erred in not granting deduction unde....
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..../-. As per the profit and loss account, the assessee had claimed an amount of Rs. 8,21,997/- as bad debt written off under the head "Other Expenses". During the course of assessment proceedings, the assessee filed before the AO the following details : Write off of Investment in Jetpur Somnath Highways Ltd. on account of winding up Rs. 7,40,000/- Irrecoverable medical Expenses written off Rs. 81,997/- Rs. 8,21,997/- However, the AO was not convinced with the above submission of the assessee on the ground that it had never offered this as income in any of the earlier assessment years. Therefore, the AO disallowed the above amount of Rs. 8,21,997/-. 3.1 In appeal, the Ld. CIT(A) affirmed the above disallowance on the groun....
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....L) and designated the same as the SPV required for undertaking the project. The assessee owned 74% of the share capital of the SPV for which it had paid Rs. 7,40,000/-. However, the NHAI rejected the application to designate JSHL as the SPV. As a result, the SPV was wound up and since no consideration was received by the assessee on account of winding up of the SPV, the entire investment in JSHL was written off. In the instant case, the write off is nothing but write off of an expenditure on an abandoned project ; the project in question had inextricable link with the assessee's existing business and hence, the expenditure is allowable as revenue expenditure u/s 37(1) of the Act. On the basis of the above reasons, we delete the disallowanc....