ORDER M.R. Shah, J. 1.00. Feeling aggrieved and dissatisfied with the judgement and order passed by the learned Income Tax Appellate Tribunal, Ahmedabad, Bench "B", in ITA No. 216/Ahd/2011 for A.Y. 2005-2006 dated 27/8/2014, revenue has preferred the present Tax Appeal with the following proposed substantial question of law :-- "Whether the Appellate Tribunal has substantially erred in partly allowing the amount of Rs. 37,00,447/- out of total disallowance of Rs. 45,31,872/- made on account of deduction in respect of writing off of the irrecoverable advances and other debit balances claimed by the assessee u/s. 36(1)(vii) of the I.T. Act?" 2.00. That the assessee Company, engaged in the business of manufacturing and trading Air-Conditioners, filed its return of income for the A.Y. 2005-2006 declaring total income at NIL. The case was selected for scrutiny. That the assessee claimed deduction in respect of the written off of the irrecoverable advances and other debit balances. The assessee written off of an amount of Rs. 14,83,037/- which was claimed as advances (EMD) and another amount of Rs. 30,48,335/- as "Balances written off". The assessee also claimed deduction of Rs. 42,51,367/- as written off of debts/bad debts. 2.01. That the A.O. disallowed the aforesaid deductions and the total income, before the adjustment of brought forward loss, was determined at Rs. 21,57,22,429/-. 2.02. That the A.O. disallowed Rs. 14,83,037/- holding that the said debts balances were not consequent to sale and therefore, does not come under the purview of section 36(1)(vii) of the I.T. Act. The A.O. also disallowed Rs. 30,48,835/- on the ground that the assessee could not substantially justify that the same were genuine written off debts. 2.03. Feeling aggrieved and dissatisfied with the assessment order passed by the A.O. disallowing the aforesaid amounts i.e. advances written off of Rs. 14,83,037/-, balance written off of Rs. 42,51,367/-, aggregating to Rs. 87,83,239/-, the assessee preferred appeal before the learned CIT(A) and the learned CIT(A) confirmed the disallowance of Rs. 14,83,037/- and Rs. 30,48,835/- made by the A.O., however, deleted the disallowance made by the A.O. of Rs. 42,51,367/- which was claimed by the assessee as bad written off. 2.04. Feeling aggrieved and dissatisfied with the order passed by the learned CIT(A) confirming the disallowance made by the A.O. of Rs. 14,83,037/- and Rs. 30,48,835/- made by the A.O., however, deleted the disallowance made by the A.O. of Rs. 42,51,367/- which was claimed by the assessee as bad written off. 2.04. Feeling aggrieved and dissatisfied with the order passed by the learned CIT(A) confirming the disallowance made by the A.O. of Rs. 14,83,037/- claimed by the assessee as written off, assessee preferred an appeal before the learned tribunal and after hearing both the sides, the learned tribunal has partly allowed the said appeal deleting the disallowance of Rs. 7.30 lacs by observing that the said amount was given towards "Employees' Welfare Trust" and the balance amount was towards EMD related to business. The learned tribunal, however, restricted disallowance. 2.05. Feeling aggrieved and dissatisfied with the order passed by the learned CIT(A) in confirming the disallowance made by the A.O. of Rs. 14,83,037/- claimed by the assessee as advances written off and disallowance of Rs. 30,48,335/-claimed by the assessee as written off, the assessee preferred appeal before the learned tribunal. 2.06. The learned tribunal, after hearing both the sides, by the impugned judgement and order has partly allowed the aforesaid appeal deleting the disallowance of Rs. 7.30 Lacs by observing that the said amount was given towards "Employees' Welfare Trust" and the balance amount was towards EMD related to business. The learned tribunal, however, restricted the disallowance to the extent of Rs. 1 Lac. 2.07. Feeling aggrieved and dissatisfied with the aforesaid impugned judgement and order passed by the learned tribunal, the revenue has preferred the present Tax Appeal with the aforesaid proposed substantial questions of law. 3.00. Having heard Mrs. Mauna Bhatt, learned advocate appearing on behalf of the revenue and considering the impugned judgement and order passed by the learned tribunal, it appears that with respect to disallowance made by the A.O. of Rs. 14,83,037/-, for which the assessee claimed deduction as advances written off, the learned tribunal has confirmed the disallowance amounting to Rs. 7,31,425/- which was with respect to the "Employees' Welfare Trust" and rest of the amount was ordered to be deleted by the learned tribunal considering the details of advance placed at page Nos. 48 and 49 of the Paper Book. 7,31,425/- which was with respect to the "Employees' Welfare Trust" and rest of the amount was ordered to be deleted by the learned tribunal considering the details of advance placed at page Nos. 48 and 49 of the Paper Book. The learned tribunal has found that the majority of the amounts were stated to be towards EMDs of which earliest amount outstanding was from the year 1997 and the last being outstanding from the year 2001. In light of the above it cannot be said that the learned tribunal has committed an error in directing to delete disallowance made by the A.O. with respect to balance amount (Rs. 14,83,037/- minus 7,31,425/-). 3.01. Now, so far as the disallowance made by the A.O. of Rs. 30,48,335/-, of which the assessee claimed deduction with respect to the written off, is concerned, the learned tribunal has restricted the disallowance to Rs. 1 Lac considering page Nos. 50 and 51 of the Paper Book and having found that the written off amount of Rs. 30,48,835/- contains various amounts which were shown to be not recoverable from the parties, however, it also included Provision for Gratuity, salary payable, PF payable, staff loan, etc., for which full details were not placed before the learned tribunal. Considering the aforesaid facts and circumstances of the case, more particularly page Nos. 50 and 51 of the Paper Book and amounts included certain amounts like Provision for Gratuity, salary payable, PF payable, staff loan, etc., when the learned tribunal has restricted the disallowance to Rs. 1 Lac, it cannot be said that the learned tribunal has committed any error. 3.02. At this stage it is required to be noted that to satisfy ourself as to the actual amount with respect to provisions for Provision for Gratuity, salary payable, PF payable, staff loan, etc., and to satisfy ourself as to, whether the learned tribunal was justified in restricting the disallowance to Rs. 1 Lac, we called upon the learned advocate appeasing on behalf of the appellant - revenue to place before us page Nos. 50 and 51 of the Paper Book. However, despite number of opportunities granted to the revenue, the revenue has failed to produce the same for perusal of this Court. However, considering the findings recorded by the learned tribunal, we confirm the disallowance restricted to Rs. 1 Lac. 4.00. 50 and 51 of the Paper Book. However, despite number of opportunities granted to the revenue, the revenue has failed to produce the same for perusal of this Court. However, considering the findings recorded by the learned tribunal, we confirm the disallowance restricted to Rs. 1 Lac. 4.00. In view of the above, no substantial question of law arise, as proposed. Under the circumstances, present Tax Appeal deserve to be dismissed and is accordingly dismissed.