JILA SAHAKARI KENDRIYA BANK MYDT VIDISHA,VIDISHA vs. DCIT/ACIT 3(1), BHOPAL, BHOPAL

ITA 988/IND/2025Status: DisposedITAT Indore10 August 2026AY 2018-1926 pages
AI SummaryRemanded

What did the Tribunal hold?

The Tribunal held that the addition of Rs. 83,78,318/- as commission income for AY 2018-19 was not sustainable as the income was ultimately received and offered for taxation in AY 2020-21 and AY 2021-22, thus avoiding double taxation. The matter was remanded for proper verification.

What were the facts?

The assessee initially offered commission income of Rs. 83,78,318/- in its original return for AY 2018-19, but later revised the return to exclude this income as it was not received and there was uncertainty of realization. The Assessing Officer made an addition of this amount, which was upheld by the CIT(A).

What were the issues?

The primary issue was the year of taxability of commission income under the mercantile system of accounting when there was uncertainty of receipt and the income was later offered in subsequent years.

Which sections of the Income-tax Act were involved?

Section 143(3),Section 250,Section 253

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, INDORE BENCH, INDORE

Before: SHRI MANISH BORAD & SHRI PARESH M. JOSHI

Per Paresh M. Joshi, JM:

This is an Appeal filed by the Revenue under section 253 of the Income tax Act 1961, [herein after referred to as the Act

for the sake of brevity] before this tribunal. The Revenue is aggrieved by the order bearing No:-ITBA/NFAC/S/250/2025-

26/1080656213(1) dated 12.09.2025 passed by the Ld.

CIT(A) u/s 250 of the Act which is hereinafter referred as the JILA SAHAKARI KENDRIYA BANK MYDT VIDISHA ITA No. 988/Ind/2025 AY-2018-2019 “Impugned Order”. The Relevant Assessment Year is 2018-

2019 and the corresponding Previous Year Period is from 01/04/2017 to 31/03/2018. 2. FACTUAL MATRIX

2.

1 That as and by way of an Assessment Order made u/s 143(3)

The order continues below.

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