TMI Blog2023 (5) TMI 1111X X X X Extracts X X X X X X X X Extracts X X X X ..... fere with the order of CIT(A) and thus the grounds of Revenue is dismissed. - ITA Nos. 1719 And 1720/Del/2022 - - - Dated:- 25-5-2023 - Sh. Anil Chaturvedi, Accountant Member And Sh. Anubhav Sharma, Judicial Member For the Assessee : Shri Divyansh Jain, Adv. For the Revenue : Shri Javed Akhtar, CIT-DR ORDER PER ANIL CHATURVEDI, AM : These two appeals filed by the Revenue are directed against the order dated 27.05.2022 passed by the Commissioner of Income Tax (Appeals) - 27, New Delhi for Assessment Years 2015-16 2017-18. 2. Before us, at the outset, both the parties submitted that though the appeals filed by the Revenue are for two different assessment years but the facts and issues involved in both the ap ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 55,62,914/- by treating the provision made for Shahenshah Scheme to be a contingent liability. 5. Aggrieved by the order of AO, assessee carried the matter before CIT(A). CIT(A) after considering the detailed submissions of the assessee deleted the addition. The deletion was deleted for the reason that in the case of assessee on identical facts in Assessment Years 2007-08, 2008-09, 2009-10 2014-15, the Tribunal had decided the issue in favour of the assessee. Aggrieved by the order of CIT(A), Revenue is now in appeal before the Tribunal and has raised the following grounds: 1. The order of the CIT(A) is erroneous and not tenable in law and on facts. 2. The Ld CIT(A) has erred in deleting addition made by the AO on Shahensh ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e before AO and CIT(A) and further submitted that identical disallowances was made by AO in the past in A.Ys. 2006-07 to 2009- 10 2014-15 and in all those years the Tribunal has decided the issue in favour of the assessee. He further submitted that in such a situation no fault can be formed to the CIT(A). He thus supported the order of CIT(A). 9. We have heard the rival submissions and perused the material available on record. The issue in the present ground is with respect to the treatment of provision made to Shahenshah Scheme. It is the contention of the Revenue that the provision made is in the nature of contingent liability and therefore not allowable for deduction. CIT(A) while deciding the issue has noted that on identical facts ..... X X X X Extracts X X X X X X X X Extracts X X X X
|
