As per the case facts the assessee a real estate developer claimed a write-off for a significant amount as a bad debt The Income Tax Appellate Tribunal and the High ... Court upheld this claim The Revenue appealed to the Supreme Court The question arose whether a provision for doubtful debt expressly excluded from Section vii could still claim deduction under Section of the Income Tax Act Finally the Supreme Court allowed the Revenue's appeal setting aside the impugned judgment of the High Court and the order of ITAT The court clarified that if an item falls under Sections to but is excluded by an explanation to Section vii then Section cannot apply meaning such a provision cannot claim deduction under Section of the Income Tax Act