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2019 (1) TMI 634 - AT - Income TaxEstimation of sale - method of accounting - Held that:- The assessee’s accounting for the current year is on the same basis as for the preceding year; rather, continues to be the same from year to year. No difference has in any case been pointed out to us, with in fact the assessing authority relying on his findings for AY 2013-14. There is, as such, no reason why our findings for that year should not hold good for the current year as well. We, accordingly, following the tribunal’s order for AY 2013-14, delete the impugned addition, of course, subject to the same observations as obtaining for that year. We decide accordingly. Disallowance of prior period expenses - claim in respect of commission expenditure (on sales) - Held that:- The assessee’s explanation of the commission arising to the payee/s only on the realization of the sale proceeds, so that the impugned expenditure in fact accrued during the current year, was found incorrect on facts. No improvement in its’ case stands made before us. The assessee has at no stage substantiated its’ case of it accounting and, accordingly, claiming the commission expense on the realization of the corresponding sale. The dates of the realization of the corresponding sale/s, which therefore assumes relevance in this regard, are conspicuous by their absence. Why, we observe no rebuttal to the findings, issued on the examination of the relevant record, by the ld. CIT(A) – who has been reasonable in allowing part relief, and the assesseee’s case completely fails on facts. The impugned disallowance is accordingly confirmed. - Decided against assessee.
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