TaxTMI 
TaxTMI 
2026 (4) TMI 399
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....ion 270A of the Income Tax Act, 1961 pertaining to Assessment Year 2017-18. The word 'Act' herein this order would mean Income Tax Act, 1961. 2. The assessee has raised following grounds of appeal:- 1. On the facts and circumstances of the case, the appellate order passed by the Hon'ble Commissioner of Income tax (Appeals), National Faceless Appeal Centre (hereinafter referred to as 'CIT(A) or 'NFAC*) dated 26 June 2025 under section 250 of the Income-tax Act, 1961 ('the Act) is bad in law. 2. On the facts and circumstances of the case and in law, the Ld. CIT(A) has erred in upholding the disallowance of IN 45,51,957 towards debtors written off and miscellaneous driver / employee balance written off with....
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.... against the Appellant on account of the addition made in the assessment order. 3. First issue raised by the ld. Counsel for the assessee is regarding the action of the ld. CIT(A) in upholding disallowance of Rs. 45,54,957/- towards debtors written off and miscellaneous driver/employee balance written of. It was contended that the ld. First Appellate Authority had failed to appreciate that the impugned amount was an expenditure wholly and exclusively for the purposes of business. 4. The ld. Counsel for the assessee argued that the issue is covered in its own case by the order of this Tribunal for AY 2013-14. It was stated that in the said assessment year, the ld. AO had made a disallowance of Rs. 15,76,774/- which was deleted by the l....
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.... the employment of the appellant company. The AR has relied upon the judgment of Hon'ble Delhi High Court in the case of CIT vs. Triveni Engg. & Industries Ltd., [2010] 8 taxmann.com 135 (Delhi) along with other decisions. On perusal of the facts of the case and the legal position on the issue as decided by the jurisdictional High Court, I am of the opinion that the facts in this case are similar and therefore, the addition made by the AO is deleted and the ground of appeal is allowed" 5. After hearing both parties we find that it is not a dispute that an amount of Rs. 15,76,774/- which were advanced to the employees and drivers had become irrecoverable and assessee has not claimed as a bad debt but as a business loss, which is cle....
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....ubmitted that the ld. CIT(A) concurred with the AO's finding qua failure to produce documents concerning efforts for recovery and confirmed the addition. 7. The ld. Counsel for the assessee vehemently argued that post the decision of Hon'ble Apex Court in the case of TRF, there is no necessity for a tax payers to establish the efforts of recovery made and that a claim of bad debts if shown as income in preceding years, would qualify the allowance. The ld. Counsel submitted that the impugned debts have been adequately reflected in the financial affairs of earlier years. 8. Per Contra, the ld. DR relied upon the order of the lower authorities. 9. We have heard rival submissions in the light of material placed on record. We have noted....