TMI Blog1977 (8) TMI 71X X X X Extracts X X X X X X X X Extracts X X X X ..... 0,890 with which the AAC agreed. The challenge against that figure of claim of the assessee is that in reaching that figure deduction of bad debt had not been allowed. The firm had by 31st December. 1968 written off a sum of Rs. 5,06,371. That was claimed as bad debts in its income-tax assessment. The ITO in assessment had allowed Rs. 43,578 as bad debts. So the WTO also accepted that figure and a ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... s what is the market value of those assets covered by those debts allowed as bad debts in income-tax assessments for 1970-71 and 1971-72 as on the valuation date 31st Dec., 1968. The position of the debts as regards the chance of recovery and solvency of debtors as on 31st Dec., 1968 and on the relevant accounting years in which it was allowed as bad debts in income-tax assessments are factually t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... of debts which made up this amount with particular regard to solvency of debtors and chance of recovery which two ingredients are the vital factors for fixation of price in a sale of a chose in action like this. After considering the relevant facts and circumstances with regard to each debt we should think that a general average of 50 per cent would reflect the real market value of these assets as ..... X X X X Extracts X X X X X X X X Extracts X X X X
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