JUDGMENT

HIDAYATULLAH J.-The assessee, A. V. Thomas and Co. Ltd., Alleppey, claimed a deduction of Rs. 4,05,072-8-6 in the assessment ear 1952-53 as a bad debt which was written off in its books of account on December 31, 1951. This claim was disallowed. After sundry procedure, the following question was considered by the High Court of Kerala and answered against the assessee company:

" Whether, on the facts and in the circumstances of the case, the Tribunal was correct in holding that the amount of Rs. 4,05,071-8-6 claimed by the assessee company as a deduction was not admissible either under section 10(2)(xi) or 10(2)(xv) ? "

The High Court certified the case as fit for appeal to this court and this appeal has been filed by the assessee company. The Commissioner of Income-tax (Bangalore), Kerala, is the respondent.

The assessee company was incorporated in 1935 and, as is usual with companies, its memorandum of association authorised it to do multifarious businesses. According to clauses 1, 5, 18 and 23 it was authorised " to be interested in, to promote and to undertake the formation and establishment of other companies", to make investments and to assist any company financially or o