M.L. Mehta, J.

1. This is an appeal under Section 260A(1) of the Income Tax Act, 1961 (for short "the Act") against the order of the Income Tax Appellate Tribunal (for short "the Tribunal") dated 3rd January, 2005 for the assessment years 1986-87. The Appellant/Assessee is engaged in the manufacturing of liquor, beer, juices, canned products and glass bottles etc. During the relevant assessment year 1986-87, the Assessee filed revised return wherein beside other things it had claimed deduction of Rs. 4,48,462/ - as un-recovered bad debts. This amount comprised of various small amounts and also a sum of Rs. 4,22,114/ - shown against Kanpur Boot House. Regarding small amounts, it is seen that they represented mostly advances given to various parties and the Assessee tried to recover but could not do so. The Assessing Officer allowed deductions of those small amounts, but declined that of Rs. 4,22,114/ - in respect of M/s. Kanpur Boot House of Shri Bhagwan Dass. He was not satisfied with the explanation given by the Assessee with regard to the reasons for being unable to recover the said amount. He disallowed the deduction observing that the Assessee had failed to produce any e