343 deduct irrecoverable loans before arriving at the profits of moneylending, and in that context stated: "The basis of the right to deduct irrecoverable loans before arriving at the profit of money lending is that to the money lender, as to the banker, money is his stock in trade or circulating capital; he is dealing in money." In Commissioner of Income tax, Madras vs Subramanya Pillai(1) a Division Bench of the Madras High Court, in explaining the principle why in money lending business allowances for bad debts were given, observed: "In the case of banking or money lending business . allowance for bad and doubtful debts was given for the reason that all the moneys embarked in the moneylending business and lent out for interest were in the nature of stock in trade of the banker or money lender and the bad and doubtful debts represented so much loss of the stock in trade.