TMI Blog2014 (11) TMI 1192X X X X Extracts X X X X X X X X Extracts X X X X ..... esent those debt in which deduction has been claimed under Section 36(1)(vii) out of the provision for bad and doubtful debts. The law laid down by the Apex Court in the case of the assessee itself (2014 (11) TMI 179 - KARNATAKA HIGH COURT) is attracted and the first substantial question of law is to be answered in favour of the assessee and against the revenue as rightly held by the Tribunal. - D ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ile basis is not taxable. The Assessing Authority held that the claim for bad debts written off is not an allowable deduction under Section 36(1)(vii) of the Act. Similarly, the claim of the assessee insofar as the interest from the Government Securities was also disallowed as the assessee was following a mercantile system of accounting and the contention of the assessee that the interest on Gover ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ii) of the Act in respect of bad debts written off of ₹ 25,95,60,772/- when the mandatory requirement of proviso to Section 36(1)(vii) contemplated that the same is limited to the amount set apart as per Clause (viia) of the Act which had been only to the extent of ₹ 22,86,23,971/- and the excess was correctly disallowed by the Assessing Officer? ii) Whether the Appellate Authoritie ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... tion of law is to be answered in favour of the assessee and against the revenue as rightly held by the Tribunal. 5. In respect of second substantial question of law is concerned, the said question is also covered by the aforesaid judgment, where the substantial question of law is answered in favour of the assessee and against the revenue. In that view of the matter, we do not find any merit ..... X X X X Extracts X X X X X X X X Extracts X X X X
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