2023 (8) TMI 1368

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....DER (PER : HONOURABLE MR.JUSTICE AKIL KURESHI) 1. Revenue is in appeal against the judgment of the Incometax Appellate Tribunal dated 16.11.2017. Following questions are presented for our consideration. "(A) Whether the Appellate Tribunal was justified in restricting the disallowance of Rs.1,28,00,000/under Section 14A of the Act to the extent of Rs.2,40,000/? (B) Whether the Appellate Tr....

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....entity where bill discounting can be accepted to be trading receipt and the resultant debt be treated as bad trading debt ? (G) Whether the Appellate Tribunal has erred in deleting the disallowance u/s.36(1)(iii) made by the AO inspite of the fact that the assessee could neither prove the nexus between the interest free funds and the advances and there was no element of commercial expediency ? ....

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....ue, we have already examined in assessee's Tax Appeals No.1022 and 1023 of 2018. No separate discussion is necessary. 3. Questions No.(C), (D), (E) and (F) pertain to the Revenue's objection to the assessee's claim of bad debt under Section 36(1)(viii) of the Incometax Act, 1961. The Tribunal examined the claim at length and accepted the assessee's stand inter alia observing that undisputedly the....