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69. The assessee was also asked to furnish the details of debtors written of with complete names and addresses and account copies so as to check whether the write off was actually made in the accounts of the individual debtors or was only a provision on an estimate basis. The details of debtors were also not furnished. However, the assessee in course of discussion, stated that this item is in the nature of provision for debtors. Apart from the unanswered queries referred above, this aspect also has a bearing on the claim. In fact, like any other provision, this does not, therefore, represent the actual write off. Under the circumstances, the claim of loss on account of 'write off' of debtors for Apple products to the tune of Rs. 1,94,43,448 is also allowable.' The appellate Commissioner of Income Tax has confirmed the disallowance by observing that the assessing authority has comprehensively dealt with the issues by discussing in detail the inability of the assessee to produce any kind of information in respect of the said debtors. It is also noticed by the appellate Commissioner of Income Tax that the appellant has also admitted that they are only in nature of provision for debtors and that the assessing authority has rightly held such claim of write off is not admissible. It is held that the action of the appellant in writing off the entire debtors without ascertaining the actual bad debt, is unsustainable in law and the disallowance is, therefore, upheld. It is submitted that both the assessing authority and the appellate Commissioner of Income Tax have rightly addressed themselves to issue regarding the disallowance of the said claim."