TMI Blog2015 (10) TMI 1420X X X X Extracts X X X X X X X X Extracts X X X X ..... o be allowed - Held that:- If the observation made in the assessment order, leading to addition made to the total income, conclusion drawn in the impugned order, material available on record, assertions made by the ld. respective counsel, if kept in juxtaposition and analyzed, we note that after 01/04/1989, it is not necessary for the assessee to establish that debt, in fact, has become irrecovera ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... : Shri M C Naniwadekar For the Respondent : Shri Neil Philip, DR ORDER Per Joginder Singh (Judicial Member) The assessee is aggrieved by the impugned order dated 20/02/2012, of the ld. First Appellate Authority, Mumbai. 2. During hearing of this appeal, the ld. counsel for the assessee, Shri M.C. Naniwadekar, did not press ground no.2 with respect to appropriated deduction u/s ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e considered the rival submissions and perused the material available on record. The fact, in brief, are that the assessee is engaged in the business of developing still graphic animation images, claimed ₹ 61,91,962/- as bad debt written off. The ld. Assessing Officer denied the claim on the ground that the debts, which were written off was only of parent company as the assessee is 100% subs ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Auto Meters Ltd. 292 ITR 345 (Del.), CIT vs Morgan Securities and Credits Pvt. Ltd. 162 taxman 124 (Del.) , Suresh Gaggal vs ITO (2009) 180 Taxman 90 (HP) , Lawlys Enterprises ltd. vs CIT 314 ITR 297 (Pat.), DIT vs Owan International Bank (2009) 184 taxman 314 (Bom.) The fact of amendment to section 36(1)(vii) read with section 36(2) is only that now for claiming deduction u/s 36(1)(vii) mere w ..... X X X X Extracts X X X X X X X X Extracts X X X X
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