DUSTERS TOTAL SOLUTIONS SERVICES PRIVATE LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX , CIRCLE-2(1)(1), BANGALORE

ITA 653/BANG/2025Status: DisposedITAT Bangalore18 December 2025AY 2020-21Bench: SHRI WASEEM AHMED (Accountant Member), SHRI KESHAV DUBEY (Judicial Member)1 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the provision for expenses was allowable as it represented an ascertained liability that had crystallised during the relevant previous year, even if invoices were received later. The disallowance made by the AO and confirmed by the CIT(A) was set aside.

What were the facts?

The assessee claimed deduction under Section 80JJAA for new employees. The Assessing Officer (AO) disallowed a portion of the claim for the previous year, citing non-manufacturing activity. For the current year, the AO disallowed the remaining claim due to lack of PAN and other documents for new employees, and incomplete Form 10DA.

What were the issues?

Whether the disallowance of deduction under Section 80JJAA for new employees was justified, and whether a provision for expenses under the mercantile system of accounting is allowable as a deduction.

Which sections of the Income-tax Act were involved?

Section 80JJAA,Section 37(1),Section 145

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Income Tax Appellate Tribunal, ‘A’ BENCH, BANGALORE

Before: SHRI WASEEM AHMED & SHRI KESHAV DUBEY

For Appellant: Smt. Kavita Jha, Advocate
For Respondent: Shri Shivanand H Kalakeri, CIT (DR)
Hearing: 04.11.2025

PER WASEEM AHMED, ACCOUNTANT MEMBER:

These appeals are filed by the assessee against the assessment order passed by the NFAC, Delhi vide order dated 17/01/2025, 21/01/2025, 27/02/2025 for the assessment year 2018-19 and 2020-21. First, we take up ITA No. 652/Bang/2025, an appeal by the assessee for the A.Y. 2018-19

ITA No.652- 653-980/Bang/2025 2. The interconnected issue raised by the assessee through Ground Nos. 1 to 9 pertains to the disallowances of deduction claimed under section 80JJAA of the Act for Rs. 14,81,19,175/- only.

3.

The relevant facts are

The order continues below.

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