PARADIP PORT AUTHORITY,JAGATSINGHPUR vs. DCIT, CIRCLE-1(1), CUTTACK
What were the facts?
The assessee created provisions for audit fees and payments to contractors at year-end. The AO disallowed these provisions as unpaid amounts remained unexplained due to missing signatures on vouchers and lack of ledger accounts. The CIT(A) confirmed these additions.
What did the Tribunal hold?
The Tribunal held that the assessee had a consistent accounting practice of creating provisions for expenses like audit fees and contractor payments, which were paid in subsequent years. Excess provisions were reversed and offered to tax. The Tribunal found the AO's disallowance and CIT(A)'s confirmation to be incorrect.
What were the issues?
Whether provisions for audit fees and contractor payments, which were subsequently paid or reversed and offered to tax, could be disallowed solely due to procedural deficiencies in documentation. Whether payments to a superannuation fund to make good a shortfall discovered through actuarial valuation are deductible.
Which sections of the Income-tax Act were involved?
AI-generated summary — verify with the full judgment below
Income Tax Appellate Tribunal, CUTTACK BENCH, CUTTACK
Before: SHRI DUVVURU RL REDDY, VP & SHRI RAJESH KUMAR, AM
Per Rajesh Kumar, AM:
These appeals preferred by the assessee against the orders of the National Faceless Appeal Centre, Delhi (hereinafter referred to as the “Ld. CIT(A)”] dated 12.08.2025, 26.08.2025, for the AYs2013-14 to 20115-16 & 2017-18. A.Y. 2013-14
The issue raised in ground no. 1 is against the confirmation of addition of ₹48,90,355/- as made by the AO in respect of provisions of audit fee at the year end. ITA Nos. 580, 581, 587 & 599/CTK/2025 PARADIP PORT AUTHORITY; A.Ys. 2013-14 to 20115-16 & 2017-18
The facts in brief are that durin
The order continues below.
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More judgments on Section 36(1)(iv)
- Crux Management Services Pvt Ltd, Hyderabad vs DCIT., Circle-1(1), HyderabadITA 1633/HYD/2025[2018-19]Status: Disposed5 Aug 2026AY 2018-19
- Paradip Port Authority, Jagatsinghpur vs DCIT, Circle-1(1), CuttackITA 599/CTK/2025[2017-18]Status: Disposed17 Jul 2026AY 2017-18
- Paradip Port Authority, Jagatsinghpur vs DCIT, Circle-1(1), CuttackITA 587/CTK/2025[2015-16]Status: Disposed17 Jul 2026AY 2015-16
- Paradip Port Authority, Jagatsinghpur vs DCIT, Circle-1(1), CuttackITA 581/CTK/2025[2014-15]Status: Disposed17 Jul 2026AY 2014-15
- Paradip Port Authority, Jagatsinghpur vs DCIT, Circle-1(1), CuttackITA 729/CTK/2025[2023-24]Status: Disposed22 Jun 2026AY 2023-24
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