2023 (5) TMI 622

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..... t : Assessee by : Shri Yogesh Shah, AR For the Respondent : Shri Rajdeep Singh, CIT DR ORDER PER SUCHITRA KAMBLE, JUDICIAL MEMBER : This Miscellaneous Application has been filed by the Assessee in respect of order dated 24.08.2022 passed by the Tribunal. 2. Ld. AR submitted that the assessee had written off bad debts amounting to Rs. 1,06,00,000/-. Out of the said amount Rs. 36,75,000/- was d .....

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..... nal in ground no.3 & 3.1. The Ld. AR submitted that the Department did not file any appeal against the CIT(A)'s order holding that in view of Supreme Court decision in case of TRF Limited, it is not necessary to establish that debt has become bad. Thus, they accepted the CIT(A)'s order that it is not necessary to establish that debt has become bad in view of TRF Limited. The Ld. AR further submitt .....

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..... ving to prove that the debt has become bad. The Ld. AR submitted that, however, the Tribunal vide paragraph no.11 confirmed the disallowance by stating that assessee had not substantiated efforts made for collecting and not established that the debt had become bad. The Ld. AR submitted that reasoning given are contrary to the decision of TRF Limited Limited which was already settled before the CIT .....

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