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8. Learned counsel for the appellant-assessee has not been able to show that the findings recorded by the Tribunal are illegal or erroneous.

9. Examining the judgments relied upon by the learned counsel for the appellant-assessee, it may be noticed that in CIT vs. Patel Brothers & Co. Limited, (1995) 215 ITR 165, the relevant assessment years were 1969- 70, 1970-71 and 1971-72. The question for consideration before the Apex Court was with regard to deduction of expenditure incurred in providing ordinary meals and refreshments to the outstation customers according to the customary hospitality and trade usage satisfying the general test of commercial expediency relating to those assessment years. It was held that the expenditure incurred by the assessees in providing ordinary meals to the outstation customers according to the established business practice was a permissible deduction inspite of sub section (2A) of Section 37 of the Act to which the assessees were entitled in the computation of their total income for the purpose of payment of tax under the Act during the relevant period prior to 1.4.1976. It was noted that the matter in question related to the period prior to 1.4.1976 and, therefore, the decision was based on sub section (2A) of Section 37 of the Act minus Explanation 2 inserted later by Finance Act, 1983 retrospectively w.e.f 1.4.1976. In New Diwan Oil Mills vs. CIT, (2009) 20 DTR Judgments 124, the assessee claimed set off of loss in the assessment year 1983-84. The revenue disallowed the claim on the ground that loss incurred on 28.3.1978 could be claimed as set off in the assessment year 1978-79 only which was not held to be justified as since assessee's civil suit was dismissed on 31.5.1982 during the financial year 1982-83, loss incurred to the assessee in that financial year only was allowed to be set off in the assessment year 1983-84. In Oriental Fire and General Insurance Co. Limited vs. CIT, (2005) 278 ITR 312 (Delhi), it was held that the reserve for bad and doubtful debts could not be added to the balance of profit disclosed in the annual accounts of the assessee for the assessment year in question. The decisions being based on individual fact situation involved therein and on the basis of the provisions applicable at the relevant time under consideration in those cases, they do not come to the rescue of the appellant-assessee. Thus, substantial questions of law are answered against the assessee. The appeal stands dismissed.