PCIT v. Watson Pharma (P) Ltd. (2025) 173 taxmann.com 957 /346 CTR 82 / 249 DTR 25 (Bom)(HC)

S. 37(1) : Business expenditure-Bad debt-Advances given in the course of business written off-Genuineness of advances not doubted-Books audited by statutory auditors-Write-off allowable as deduction-Order of Tribunal affirmed. [S. 28(i), 36(1)(vii), 260A]

The assessee had written off advances given to more than 50 parties in the course of business on the ground that the amounts had become irrecoverable or no services were received. The Tribunal allowed the claim after noting that the genuineness of the advances was never doubted by the Revenue and that the books of account were duly audited. The High Court observed that the DRP had failed to consider detailed evidences furnished by the assessee vide letter dated 4-3-2014 and its observation that the claim lacked evidence was incorrect. Considering that the assessee had declared income exceeding Rs. 30 crore and the net write-off was only Rs. 7,66,713 involving small advances, the Tribunal’s view allowing deduction was reasonable and justified. Accordingly, no substantial question of law arose and the order of the Tribunal was affirmed. (AY. 2010–11).

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