TMI Blog2023 (2) TMI 156X X X X Extracts X X X X X X X X Extracts X X X X ..... of the appellant that the corresponding entire income has been offered to tax. The ratio of the decisions of Rotork Controls India (P.) Ltd. [ 2009 (5) TMI 16 - SUPREME COURT] and Bharat Earth Movers Ltd. [ 2000 (8) TMI 4 - SUPREME COURT] laid down by the ld. AR have no application to the facts of the present case. CIT(A) had rightly held that when the case was taken up for scrutiny under Limited Scrutiny for the purpose of verification of low income, verification of expenses also falls within its sweep. Thus, we are of the considered opinion that the provision for expenses as claimed by the assessee was rightly disallowed by the Assessing Officer. Accordingly, the order of the ld. CIT(A) is based on proper appreciation of facts of ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... t nature and cannot be allowed as deduction. 3. Being aggrieved by the above disallowance, an appeal was filed before the ld. CIT(A) contending inter alia that when the case was selected for limited scrutiny, the Assessing Officer cannot travel beyond the issues for which the case was selected for scrutiny assessment. Without prejudice to the above, it is contended that the provision of expenses should be allowed as deduction, as the provision of expenses was made based on the certificate issued by the Architect. However, the ld. CIT(A) dismissed the appeal by giving the finding that the appellant had failed to demonstrate that the expenses for which the provision was created were actually incurred in the subsequent period. The ld. CIT(A ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ses in proportionate to the completion of the contracted project, which means the question of providing for expenses to be incurred in future does not arise. It is neither the case of the appellant that the corresponding entire income has been offered to tax. The ratio of the decisions of the Hon ble Supreme Court in the case of Rotork Controls India (P.) Ltd. (supra) and Bharat Earth Movers Ltd. laid down by the ld. AR have no application to the facts of the present case. The CIT(A) had rightly held that when the case was taken up for scrutiny under Limited Scrutiny for the purpose of verification of low income, verification of expenses also falls within its sweep. Thus, we are of the considered opinion that the provision for expenses as ..... X X X X Extracts X X X X X X X X Extracts X X X X
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