Triumph International (India) Pvt. Ltd. v. ACIT (2022)100 ITR 33 (SN)(Chennai) (Trib)

S. 36(1)(viia) : Bad debt-Provision for bad and doubtful debts-No deduction is allowable on mere provision on gross basis-Bad debts should be actually written off in books of account-Matter remanded.

Held, that no deduction could be granted under section 36(1)(viia) on mere provision. The condition to claim bad debts was that the debts should actually be written off in the books of account. The provision made on gross basis without identifying the specific debtors would not entitle the assessee to claim this deduction. Since the Dispute Resolution Panel had not dealt with this issue and to bring on record the correct factual matrix, this issue was restored to the Assessing Officer for fresh adjudication with a direction to the assessee to substantiate its stand. (AY.2010-11, 2011-12)