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The Grounds of appeal raised by the assessee— 1.Deduction in respect of waiver of Advances of Rs. 15,11,15,380/- 2.Claim of Short term Capital Loss (Rs. 6,93,040) and Long Term Capital Loss (Rs. 1,29,78,811) on sale of R & D Assets 3.Claim of special pension liability based_on actuarial valuation of 1,27,75,558/-: 4.Addition on account of Unutilised Modvat Credit of Rs. 17,13.97,0887- 5.Claim of deduction U/s. 80HHC on certain receipts

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Section 36(1)(vii)  & 36(2) of the Income-tax Act, 1961—Bad debts— Income offered by the assessee in the form of interest and assignment charges formed part of the entire debt owned by the assessee from NGE and since the assessee had offered to tax a part of the debt, the requirement of Section 36(2) stood satisfied and the assessee is eligible to claim the deduction of Rs. 15,11,15,380/- under Section 36(1)(vii).  When only the interest income was offered to tax by the assessee and not the loan itself, the requirement of Section 36(2)(i) is satisfied even though the principal amount of loan was not offered to tax as the interest represents the part of the debt and Section 36(2)(i) of the Act states that "debt or part thereof" shall be offered to tax — Mahindra & Mahindra Ltd. vs. Dy. CIT.[2020] 180 ITD 776 (MUM)

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