Held that under compelling circumstances as by the direction of the Reserve Bank of India such loans were converted into preference shares which consequently eroded in value because of the loss sustained by the subsidiary. Therefore, the Tribunal rightly held that merely because the loss was debited under the nomenclature “provision” that did not alter the basic character of the transaction and the loss incurred due to non-recoverability of the amount advanced in the ordinary course of business could not have been disallowed by the Assessing Officer. (AY.2012-13)