Section 36(1)(vii) and 36(1)(viia) are separate, distinct and independent from each other

The Assessing Officer disallowed the bad debts written off of Rs. 20,24,842/- on the ground that the amount of deduction claimed and allowed under the provisions of Section 36(1)(viia) of the Act for bad and doubtful debts of Rs. 3 8,00,870/- is more than the bad debts claimed and also on the ground that the bad debts claimed pertained to the period when the appellant claimed deduction under section 80P of the Act. The Commissioner of Income Tax (Appeals) also upheld the addition holding that the claim for deduction of bad debts were not allowable as the same is

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