SHUBHAM AGENCIES,INDORE vs. DCIT/ACIT-4(1), INDORE, INDORE

ITA 46/IND/2026Status: DisposedITAT Indore14 May 2026AY 2022-2311 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the entire exercise of disturbing the year of allowability of expenditure would be revenue neutral as the expenditure was genuine and incurred for business. The Tribunal relied on judicial precedents that emphasize the year of taxability of an amount when the expenditure is genuine.

What were the facts?

The assessee claimed interest expenses of Rs. 5,20,875/- on loans taken. The Assessing Officer disallowed Rs. 2,37,375/- as excess interest for the period, stating it should be deferred to the next assessment year. The CIT(A) upheld this disallowance.

What were the issues?

The key issue was whether the excess interest claimed should be disallowed in the current year or allowed in a subsequent year, and whether the disallowance was revenue neutral.

Which sections of the Income-tax Act were involved?

Section 143(3),Section 144B,Section 250,Section 253,Section 36(1)(iii),Section 37(1)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, INDORE BENCH, INDORE

For Appellant: Shri Kunal
For Respondent: Shri Ashish Porwal, Sr.DR
Hearing: 06.05.2026Pronounced: 14.05.2026

Per Paresh M Joshi, J.M.:

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

for the sake of brevity] before this tribunal as & by way of a second Appeal. The Assessee is aggrieved by the order

bearingNumber:-ITBA/NFAC/S/250/2025-26/1082612225

(1) dated 14.11.2025 passed by the Ld. CIT(A) u/s 250 of the Act, which is herein after referred to as the “Impugned

order”. The Relevant Assessment year is 2022-23 and the Shubham Agencies ITA No. 46/Ind/2026 - A.Y.2022-23

corresponding previous year period is from 01.04.2021 to 31.03.2022. 2. Factual Matrix

2.

1 That as and by way of an assessment order made u/s 143(3) rws

The order continues below.

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