TMI Blog2015 (4) TMI 174X X X X Extracts X X X X X X X X Extracts X X X X ..... as u/s. 43B(f). Therefore, the said disallowance is justified. In view of this, we are inclined to decide the issue against the assessee. Whether on facts and circumstances of the case, the CIT(A) erred in confirming the action of the Assessing officer in assessing interest/commission received upfront on inland/export bills purchased/discounted/LCs opened - Held that:- assessee has transferred an amount of ₹ 27.64 crores towards other liabilities out of the interest received upfront on inland bills and export bills purchased/discounted. Though initially, the full amount received is credited to the P&L account as it was received by the assessee, at the time of preparing final accounts, proportionate interest relating to the remainin ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... he Assessing officer in assessing interest/commission received upfront on inland/export bills purchased/discounted/LCs opened. 3. The Assessing officer has made the disallowance of leave encashment at ₹ 24.37 crores by observing that this is only a provision based on vague and subjective assumption and no amount was paid and it is neither accrued nor existing liability and it is not capable of being accurately determined. 4. On appeal, the CIT(A) confirmed the order of the Assessing officer. Against this, the assessee is on appeal before us. 5. We have heard both the parties and perused the record. We find that this issue is fully covered by the judgment of the Hon ble Kerala High Court in the case of the South Indian Bank Lt ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ficer ought not to have unnecessarily disturbed the method of accounting consistently without any valid reason. 7. The CIT(A) observed that since the assessee is only discounting the bill, the transaction is completed at the point of discounting of bill and the income accrues to the assessee at that point and hence, confirmed the addition made by the Assessing Officer. 8. According to the Ld. AR income though received upfront is actually relatable to a period of time and is offered on period basis for the next assessment year and accordingly, submitted that the addition be deleted. 9. On the other hand, the Ld. DR submitted that since the assessee is in the relationship to borrower who discounts the bill, the transaction is complet ..... X X X X Extracts X X X X X X X X Extracts X X X X
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