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2019 (1) TMI 746 - ITAT LUCKNOWAccrual of income - Assessment of income of coupons and corresponding expenses - existence of element of profit - as during assessment year 2007-08 the assessee had already claimed TDS but the corresponding receipt was not incorporated in the income - allowing income aspect in earlier year and not allowing corresponding expenses in the same year - CIT(A) has held that the deductor Idea had duly deducted TDS and had issued credit notes in favour of the assessee, however noted that the assessee had duly claimed the recharged coupons as expenses when these were distributed by him in the next year - Held that:- CIT(A), in his findings, has ignored the fact that assessee, on the one had had claimed expenses in the next year against the recharged coupons and therefore, there was no wrong on the part of the assessee in declaring the corresponding income in the next year. As find from the copy of ledger account,assessee had credited the income on account of coupons on 04/04/2007 to 05/04/2007 and has also claimed free of cost recharged coupons as expenses. The entries passed by the assessee in the succeeding year relate to recording of income as well as expenses. The action of authorities below by taking only the income aspect in earlier year and not allowing corresponding expenses in the same year is not justified. The addition, if sustained, will result into double addition as the assessee himself during succeeding year has credited the same amount in the books of account and therefore, the action of authorities below in making and sustaining the addition in the year under consideration is not justified. - Decided in favour of assessee.
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