N N Sippy Productions Pvt Ltd, Mumbai vs. ITO Ward 13(1)(1), Mumbai
In the result, the appeal is allowed for statistical purposes
ITA 4961/MUM/2025[2020-21]Status: DisposedITAT Mumbai03 Feb 2026AY 2020-21
Bench: Shri Narender Kumar Choudhry & Shri Prabhash Shankarn.N. Sippy Productions V/S. Income Tax Officer – 13(1)(1) Private Limited बनाम 225, Aaykar Bhavan, M.K. A4, Shalimar Chs, Road, Mumbai – 400 054, Santacruz, Mumbai – Maharashtra 400054, Maharashtra स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aagcn6412N Appellant/अपीलार्थी .. Respondent/प्रतिवादी
For Appellant: Shri Mehul Talera, ARFor Respondent: Shri Leyaqat Ali Aafaqui, (Sr. DR)
Section 133ASection 147Section 250Section 68
…The same stand is as per accounting standard and department had been consistently accepting the same accounting treatment, revenue recognition, tax treatment across years. In this regard, Reliance is placed on the decision in case of CIT v K. E. Gnanavelraja (361 ITR 446) (Mad) upheld that advance money received towards distribution of films which was offered as income in subsequent years cannot be subject to S.68 and is in the ordinary course of business. Further, this modus operandi is well known and widely accepted by Revenue at large. 5.2 It was submitted that entire dispute is arising out of offshoot of sur…