P.MOHANARAJAN, A.KALYANASUNDHARAM
Overseas Sanmar Financial Ltd. – Appellant
Versus
Joint Commissioner of Income-tax – Respondent
Per A. Kalyanasundharam, Senior Vice President. - The assessee, a non-banking financial company, has filed these two appeals aggrieved by the orders of the Commissioner of Income-tax (Appeals) - II, Chennai [CIT(A) for short] dated 9-11-1998 and 27-7-1999 respectively. These two appeals involve a common issue that is concerned with the claim for deduction from total income the provision made for doubtful advances categorized as Non-Performing Assets under the guidelines issued by the Reserve Bank of India [RBI for short] covering all Non-Banking Financial Companies [NBFC for short]. The issues in both appeals involve appreciation of the concept of income and its computation with reference to the provisions of Income-tax Act, 1961 [hereinafter referred to as the Act]. Considering the fact that the appeals involve a common issue, the two appeals are grouped together, heard together and are disposed of by this common order.
2. There are few issues in both the appeals that are specific to an assessment year and by means of this order we first shall deal with these independent issues in the order in which it has been so raised in the grounds of appeal. These independent issues shall
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