Sanmar Speciality Chemicals Ltd., Chennai vs. DCIT, Chennai
In the result, appeal filed by the assessee is treated as allowed for statistical purposes
ITA 392/CHNY/2019[2014-15]Status: DisposedITAT Chennai31 Jan 2023AY 2014-15
Bench: Shri V. Durga Rao, Hon’Ble & Shri G. Manjunatha, Hon’Bleआयकर अपील सं./Ita No.: 392/Chny/2019 िनधा"रण वष" / Assessment Year: 2014-15 Sanmar Speciality Chemicals Deputy Commissioner Of Limited, V. Income-Tax, 9 Cathedral Road, Corporate Circle 6(1), Chennai 600 086. Chennai. [Pan: Aabcs-0201-P] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri. R. Vijayaraghavan, Advocate ""यथ" क" ओर से/Respondent By : Shri. P. Sajit Kumar, Jcit सुनवाई क" तारीख/Date Of Hearing : 01.12.2022 घोषणा क" तारीख/Date Of Pronouncement : 31.01.2023
For Appellant: Shri. R. Vijayaraghavan, AdvocateFor Respondent: Shri. P. Sajit Kumar, JCIT
Section 144A
…e and the question of reopening of books does not arise. g) The learned Deputy Commissioner erred in coming to the conclusion that a contractual liability crystallizes only at the time of settlement based on the decision of Alembic Chemical Works Ltd Vs CIT - 266 ITR 47 as in the decision of Alembic Chemical Works Ltd, the issue was whether the liability was in the nature of contingent or not which could not be allowed as expenses, whereas in the case of the Appellant the price difference was based on the formula as agreed between the Parties. h) The learned Deputy Commissioner of Income tax erred in not followin…