The amount written off did not arise on account of sales but from the payment made on account of advance for purchase of stock-in-trade and not of any kind of fixed asset. He also dismissed the alternative plea for allowability under section 28 of the Act on the ground that the write-off was within three years and confirmed the action of the Assessing Officer. It was held that there was no dispute that the amount written off had been paid as an advance for the purchase of material for stock-in-trade. Advances written off were to be allowed. Allowable as deduction.  (AY. 2012-13)