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Appeals are partly allowed.We are also not convinced with other arguments of Ld. AR that the deduction should be allowed as bad debts since the same would be governed by the requirements of Section 36(1)(vii).

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Section 36(1)(viii) of the Income Tax Act, 1961 — Business Expenditure — Bad debts — Reserves are created as an appropriation out of profit and loss account and terms profit and loss account and general reserves as mentioned in proviso to section 36(1)(viii) cannot be equated with each other. Balance in profit and loss account which is not in nature of any other reserve having specific objectives would not form part of 'general reserves 'for purpose of proviso to section 36(1)(viii) — LIC Housing Finance Ltd. vs. Deputy Commissioner of income tax [2020] 180 ITD 45 (Mumbai-trib)

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