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2021 (4) TMI 670 - AT - Income TaxBad debts - Disallowance of deduction claimed in respect of notional interest taxed as income in earlier year, which was not realized by the appellant - assessee claimed this amount of interest as deductible amount either as a bad debts or business loss under section 36(1)(vii) and/or section 28 by filing revised return - AO rejected the claim of assessee on the ground that principal amount is recovered - HELD THAT:- We have noted that for claiming the said amount the assessee has not fulfilled the condition prescribed under section 36(2) for claiming bad debts meaning thereby the assessee has not offered the said notional income as its income in earlier years. Hence, the assessee is not eligible for deduction of bad debts. Similarly, it was never the claim of the assessee that the inter corporate deposit was given for business purpose. Even otherwise, the assessee is not in money lending, therefore, the assessee cannot claim that the assessee made inter corporate deposit in the course of his business. During the earlier years the assessee never claimed as a business loss on account of non-receipt of interest on such inter corporate deposit, therefore, the assessee is also not entitled for business loss as well. - Decided against assessee.
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