Mahindra & Mahindra Ltd. v. Dy.CIT (2018) 193 TTJ 618 (Mum.)(Trib.)

S. 28(i) : Business loss-Write off of advances made for running and development of business is held to be allowable as deduction. [S. 37(1)]

Tribunal held that basic analogy for allowing write-off was to consider real nature of transaction. Advances were made for running of business and Expenditure was not incurred for new project, neither it was totally disconnected with business activities carried out by assessee. Accordingly, Tribunal held that amount was advanced for tractor division of assessee in normal course of business and is allowable. (AY. 2002-03, 2003-04)