H.K.BOSE, C.J.

1. This is an application for a certificate under Art. 133(1) of the Constitution in respect of an order of a division bench of this Court passed upon an application made under s. 66(2) of the Indian IT Act.

2. The petitioner company lent and advanced certain sums of money to a company known as Vishnu Industrial Co. (P) Ltd., New Delhi, and the interest which the petitioner company received in respect of the loans was duly assessed by the IT authorities as interest on investment under s. 10 of the IT Act. The said Vishnu Industrial Co. (P) Ltd. went into liquidation on 29th Sept., 1954. At that time a sum of Rs. 2,85,792 was found due and payable by the said company to the petitioner company. In its return submitted to the IT authorities in respect of the asst. yr. 1955-56 (accounting year 1954-55) the said sum of Rs. 2,85,792 was sought to be written off as bad debt. The ITO, Companies District II, however, by his order, dt. 29th Dec., 1955, rejected the claim of the petitioner company to write off the said sum of Rs. 2,85,792 as bad debt. The petitioner company thereupon preferred an appeal to the AAC, but this was dismissed on 23rd July, 1957. An appeal pr