Suhas Chandra Sen, J. - (1.)The Tribunal has referred the following question of law to this court under Section 256(1) of the Income-tax Act, 1961 ("the Act") :
"Whether, on the facts and in the circumstances of the case and on a proper interpretation of the relevant provisions of the Income-tax Act, 1961, the Appellate Tribunal was right in holding that the Appellate Assistant Commissioner was correct in allowing provision for doubtful debts amounting to Rs. 20,00,461 as a deduction in computing the total income of the assessee."

(2.)The relevant assessment year is 1974-75 for which the corresponding year of account was the previous year ended on March 31, 1974.
(3.)It has been stated by the Tribunal in the statement of case that the assessee was Jardine Henderson Ltd. The returned income as per the revised return was Rs. 18,83,150. The total income as per the draft assessment order was determined at Rs. 41,58,070. As the addition exceeded Rs. 1 lakh, a copy of the draft assessment order was served on the assessee, which is a limited company, for submission of its objections, if any. The assessee-company submitted their objections on February 14, 1977. Thereafter, with the approval and instructions of the Inspecting Assistant Commissioner, the Income-tax Officer made the assessment under Section 143(3) read with Section 144B of the Act.