TMI Blog1991 (7) TMI 21X X X X Extracts X X X X X X X X Extracts X X X X ..... ion ? 2. Whether, the Income-tax Appellate Tribunal was justified in not allowing the claim of bad debts in the accounts of M/s. Andrews Erectors, Obra, and Shri Ram Prakash Sharma during the year in question when the amounts were written off and its bona fides were not in dispute ? 3. Whether the Income-tax Appellate Tribunal relying on the letters of the Tahsildar dated 15th February, 1981, based on a letter from Hindustan Steel Works and Construction dated December 29, 1980, was not wrong and misdirected in finding that the bad debt of M/s. Andrews Erectors fell beyond the date of February, 1981 ? 4. Whether the letter dated December 29, 1980, of Hindustan Steel Works and Construction, referred to by the Tahsildar was not sufficien ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... financial condition ? 10. Whether, under the facts and circumstances of the case, not charging of interest on such sticky accounts was not a bona fide change of system of accounting for these accounts from mercantile to cash system and whether the Income-tax Appellate Tribunal was justified in holding that there was no change in the system of accounting ? 11. Whether the Income-tax Appellate Tribunal was justified in finding that there could not be a change in the system of accounting for certain transactions in money-lending business and thereby not accepting the cash system of accounting for sticky accounts ? 12. Whether the finding of the Income-tax Appellate Tribunal was not perverse in holding that there was no change in the sys ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ee no infirmity in the said finding recorded by the Incometax Appellate Tribunal. Questions Nos. 7 to 12 raised by the assessee relate to the interest on account of sticky advances. From a perusal of the appellate order of the Income-tax Appellate Tribunal, it is clear that the stand taken by the assessee in this regard before the Income-tax Appellate Tribunal was that although the system of accounting was mercantile, yet with regard to the sticky loans in question, i.e., for certain transactions, the contention of the assessee was that it should be assessed on the cash system of accounting. This argument has been repelled by the Income-tax Appellate Tribunal. In doing so, in our opinion, the Tribunal has not committed any error of law. F ..... X X X X Extracts X X X X X X X X Extracts X X X X
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