2022 (6) TMI 62

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....ts and circumstances of the case, the Ld. CIT(A)-4, Kolkata erred in deleting the addition made by the AO regarding provision for impairment loss of Rs. 7,77,70,000/- without appreciating the findings brought on record by the AO. 2. That on the facts and circumstances of the case, the Ld. CIT(A)-4, Kolkata erred in deleting the addition made by the AO regarding sundry balance written off amounting to Rs. 8,56,692/-. 3. That the appellant craves to add, delete or modify any of the grounds of appeal before or at the time of hearing. 3. The issue raised in ground no. 1 is against the deletion of addition by the Ld. CIT(A) as made by the AO on account of provision for impairment of loss of Rs. 7,77,70,000/-. 4. The facts....

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....tered Valuer while allowing the appeal on this issue. 5. After hearing the rival parties and perusing the material on record, we find that the deletion of addition by ld CIT(A) on account of loss resulting from impairment of fixed assets based on the valuation done by Government Registered approved Valuer is not in consonance with the provisions of the Act. The ld Counsel of the assessee referred to the provisions of section 41(2) of the Income Tax Act, 1961 (hereinafter referred to as the Act) when he was queried that under what provisions of the Act the loss on impairment in the value of fixed assets was claimed. We have perused the provisions of section 41(2) of the Act carefully and in our view the section deals with the loss arising....

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....the Ld. CIT(A) by allowing the ground no. 1 raised by the revenue. 6. The issue raised in ground no. 2 is against the deletion of addition by the Ld. CIT(A) of Rs. 84,56,692/- as made by the AO on account sundry balance written off. 7. Facts in brief are that during the assessment proceedings, the AO noted that the assessee has written off Rs. 84,56,692/- under the head sundry balances and charged the same to the profit and loss account. Accordingly, the assessee was called upon to file the details of such claim as debited by the assessee. The assessee replied to the AO vide written submission dated 20.03.2014 submitting that the claim comprised of sundry balances wriiten off as well as stocks written off however wrongly claimed under....