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2021 (3) TMI 924 - AT - Income TaxDisallowance of deduction of debit note - debit note was stated to have been issued on 18.11.2015 after the end of the financial year, and after the return was filed, and the assessee had not made any provision towards this expenditure, and had failed to demonstrate that the liability crystallized during the year under consideration - CIT-A deleted the addition - HELD THAT:- We find no error in the process of reasoning adopted by the CIT(A) as noted above. It was inter alia noted by the CIT(A) that debit note issued by supplier (GAIL) for purchase relates to F.Y. 2014-15 on account of difference in gas price. Thus, without taking into account, the extra price payable to the gas supplier, the true and fair state of affairs of the assessee society cannot be deduced. Hence, we see no reason to interfere with the tax neutral claim made by the assessee. It is not the case of the Revenue that expenditure is not bona fide and not allowable at all. The expenditure, in view of the AO, is probably allowable in the next assessment year i.e. AY 2016-17 with which we do not concur. The action of the CIT(A) is completely rational and thus endorsed. Decided against revenue.
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