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2019 (4) TMI 276 - AT - Income TaxDisallowance of year-end accruals - accruals created towards normal business expenditure incurred by the Appellant - assessee follows mercantile system of accounting accruals in accordance with 'matching principle' - HELD THAT:- As relying on previous AYs [2018 (11) TMI 130 - ITAT DELHI] and [2018 (4) TMI 33 - ITAT DELHI] in the present Assessment Year as well the Assessing Officer has not pointed out any mistake in the calculation nor there was case by the Revenue that assessee has not paid certain bills. In fact during the financial year relevant to the said assessment year, the assessee had accounted all the expenses relatable to the subject Financial Year for which bills/invoices would have been received/paid after close of the Financial Year by way of year ending accruals. Thus, the issue is identical in the present assessment year as well, hence Ground No. 1 is allowed. Addition on account of non-charging of mark up on support services charges able to AGNS - HELD THAT:- The assessee as well as AGNSI are profit making entities and there was no tax incentives earned by the assessee at any point of time. Thus, charging of mark up on support service charges which were billed to AGNSI was not correct on part of the Assessing Officer. Besides that, the issue is squarely covered in assessee’s own case for A.Y. 2010-11[2018 (4) TMI 33 - ITAT DELHI]. Hence, Ground No. 2 is allowed. Addition on account of non deduction of TDS on reimbursement of salary - HELD THAT:- The employees seconded to the assessee company are working as the employees of the assessee company, their salary is subject to TDS u/s 192 of the Act and, therefore, provisions of section 195 are not applicable on the facts of the case in hand. Thus, the issue is squarely covered by the order of the Tribunal in assessee’s own case [2018 (11) TMI 130 - ITAT DELHI]. Hence, Ground No. 3 is allowed.
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