M/S. ANDERSON GREENWOOD CROSBY SANMAR LTD.,,CHENNAI vs. ADDL. DIRECTOR OF INCOME TAX, CPC, , BANGALORE

ITA 1291/CHNY/2024Status: DisposedITAT Chennai31 December 2024AY 2021-22Bench: SHRI ABY T. VARKEY (Judicial Member), SHRI JAGADISH (Accountant Member)6 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the assessee had already offered the income for taxation by including the net amounts in its profit and loss account. The difference arose due to reporting conventions in the financial statements versus the tax audit report.

What were the facts?

The assessee offered net recovery of bad debts and write-back of liabilities in its financial statements. The Tax Audit Report (Form 3CD) showed gross amounts for these items, leading to a mismatch identified by the CPC and confirmed by the CIT(A).

What were the issues?

Whether the addition made by the CPC and confirmed by the CIT(A) was justified when the assessee had already offered the income for taxation in its books of accounts, despite a difference in gross vs. net reporting between financial statements and the tax audit report.

Which sections of the Income-tax Act were involved?

Section 41(4),Section 41(1),Section 28,Section 36(1)(vii)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, ‘A’ BENCH: CHENNAI

Before: SHRI ABY T. VARKEY & SHRI JAGADISH

Hearing: 09.10.2024Pronounced: 31.12.2024

PER JAGADISH, A.M :

Aforesaid appeal filed by the assessee for Assessment Year (AY) 2021-22 arises out of the order of Learned Commissioner of Income Tax, Addl/JCIT(A), Aurangabad [hereinafter “CIT(A)”] dated 20.03.2024. The grounds of appeal raised by the assessee are as under: :- 2 -:

1.

The order of AddI/JCIT (A) Aurangabad, under section 250 of the Income tax Act is contrary to the law, facts and circumstances of the case.

2.

The learned AddI/JCIT (A) Auran

The order continues below.

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