CIT v. Woodward Governor India Pvt. Ltd.

312 ITR 254Supreme Court of India2009#45 most cited

What is CIT v. Woodward Governor India Pvt. Ltd. authority for?

Foreign exchange fluctuations, whether gains or losses, are inextricably linked to the underlying business transaction and must be accounted for under the mercantile system. The Supreme Court also affirmed the standard accounting principle of valuing stock at cost or net realisable value, whichever is lower.

968

judgments rely on this decision, according to BharatTax’s citation analysis of 371,960 Indian tax judgments — from 2008 to 2026.

Also referred to as

CIT v. Woodward Governor · 312 ITR 254 · Section 37(1) · Section 43A · Section 145(3) · foreign exchange fluctuation · mercantile system of accounting · stock valuation · closing stock · revenue expenditure

Also reported as

21 DTR 106

Sections most often in play

Section 37(1)Section 143(3)Section 14ASection 115JBSection 147Section 142(1)Section 43(5)Section 40(a)(ia)
Read the full judgment

Issues it is cited on

section 43asection 40(a)(i)mercantile system of accountingbook profitssection 37(1)section 115jrevenue expendituresection 43capital expendituresection 40(a)section 115jbsection 32

Judgments citing CIT v. Woodward Governor India Pvt. Ltd.

Concentrix Services India Private Limited (Formerly Known As Minacs Private Limited, Minacs Limited & Adity Birla Minacs Worldwide Limited ), Mumbai vs. Joint Commissioner of It (OSD)10(2)(2)Assistant Commissioner of Income Tax-9(2)(2), Mumbai

ITA 5764/MUM/2017[2012-13]Status: DisposedITAT Mumbai18 Oct 2023AY 2012-13
For Appellant: Shri Yogesh TharFor Respondent: Shri Ajit Pal Singh Daia
Section 143(3)Section 144C(3)Section 92(1)Section 92B

…by the tribunal in paragraphs 9.2.7 to 9.2.8 of the tribunal and reliance has been placed on decisions in 'Madras Industrial Investment Corpn. Ltd. v. CIT [1997] 91 Taxman 340/225 ITR 802 (SC), CIT v. Woodward Governor (India) (P.) Ltd., [2009] 179 Taxman 326/312 ITR 254 (SC). It is also urged that discount on issue of ESOPs is only a form of compensation paid to the employee & ITA No. 5823/Mum/2019 AY 2011-12 & 2012-13 & AY 2013-14 and if not a short capital receipt. It is also urged that deduction of discount on ESOP over the vesting period is in accordance with the accounting in the books of account, which we…

Concentrix Services India Private Limited (Formerly Known As Minacs Private Limited, Minacs Limited & Adity Birla Minacs Worldwide Limited ), Mumbai vs. Deputy Commissioner of Income Tax-10(2)(2), Mumbai

ITA 5260/MUM/2017[2011-12]Status: DisposedITAT Mumbai18 Oct 2023AY 2011-12
For Appellant: Shri Yogesh TharFor Respondent: Shri Ajit Pal Singh Daia
Section 143(3)Section 144C(3)Section 92(1)Section 92B

…by the tribunal in paragraphs 9.2.7 to 9.2.8 of the tribunal and reliance has been placed on decisions in 'Madras Industrial Investment Corpn. Ltd. v. CIT [1997] 91 Taxman 340/225 ITR 802 (SC), CIT v. Woodward Governor (India) (P.) Ltd., [2009] 179 Taxman 326/312 ITR 254 (SC). It is also urged that discount on issue of ESOPs is only a form of compensation paid to the employee & ITA No. 5823/Mum/2019 AY 2011-12 & 2012-13 & AY 2013-14 and if not a short capital receipt. It is also urged that deduction of discount on ESOP over the vesting period is in accordance with the accounting in the books of account, which we…

Addl. CIT-(08), New Delhi vs. Sopra India Pvt. Ltd., New Delhi

In the result, appeal of the Revenue thus is dismissed

ITA 1175/DEL/2019[2012-13]Status: DisposedITAT Delhi16 Oct 2023AY 2012-13
Section 143(3)Section 145

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘G’, NEW DELHI BEFORE, SH. CHANDRA MOHAN GARG, JUDICIAL MEMBER AND SH. PRADIP KUMAR KEDIA, ACCOUNTANT MEMBER ACIT(08) Vs. Sopra India Pvt. Ltd. New Delhi 190, SFS, Hauz Khas, New Delhi – 110 016 PAN No. AAACM 1762 C (APPELLANT) (RESPONDENT) Assessee by Shri Neeraj Jain, Adv. & Shri Himanshu Goel, C.A. Revenue by Shri Anuj Garg, Sr. D.R. Date of hearing: 10.10.2023 Date of Pronouncement: 16.10.2023 ORDER PER PRADIP KUMAR KEDIA, AM : The captioned appeal has been filed by the Revenue against the First Appellate Order of the Learned Commissioner of Income Tax (Appea…

Joint Commissioner of Income Tax, Special Range, Panaji vs. Goa Carbon Ltd., Panaji

In the result, both the appeals of the Revenue are allowed for statistical purposes

ITA 178/PAN/2019[2016-17]Status: DisposedITAT Panaji20 Sept 2023AY 2016-17

Bench: Shri Inturi Rama Rao & Shri Partha Sarathi Chaudhury(Through Virtual Hearing)

For Appellant: Shri Mihir NaniwadekarFor Respondent: Shri Prabhakar Anand DJ, DR
Section 37(1)

…s settled position of law that loss suffered on account of fluctuation in rates of foreign exchange is allowable as a business expenditure under sec. 37(1) of the Act as held by the Hon’ble Supreme Court in the case of CIT Vs. Woodward Governor India P. Ltd., 312 ITR 254. Further, the Hon’ble Bombay High Court in the case of CIT Vs. Badridas Gauridu (P) Ltd., 261 ITR 256 has held that loss due to fluctuation in foreign exchange while implementing the export contracts was expenditure incurred towards the business of the assessee and allowable deduction under sec. 37(1) of the Act. Recently, the Chennai Bench of th…

Joint Commissioner of Income Tax, Special Range, Panaji vs. Goa Carbon Ltd., Panaji

In the result, both the appeals of the Revenue are allowed for statistical purposes

ITA 177/PAN/2019[2013-14]Status: DisposedITAT Panaji20 Sept 2023AY 2013-14

Bench: Shri Inturi Rama Rao & Shri Partha Sarathi Chaudhury(Through Virtual Hearing)

For Appellant: Shri Mihir NaniwadekarFor Respondent: Shri Prabhakar Anand DJ, DR
Section 37(1)

…s settled position of law that loss suffered on account of fluctuation in rates of foreign exchange is allowable as a business expenditure under sec. 37(1) of the Act as held by the Hon’ble Supreme Court in the case of CIT Vs. Woodward Governor India P. Ltd., 312 ITR 254. Further, the Hon’ble Bombay High Court in the case of CIT Vs. Badridas Gauridu (P) Ltd., 261 ITR 256 has held that loss due to fluctuation in foreign exchange while implementing the export contracts was expenditure incurred towards the business of the assessee and allowable deduction under sec. 37(1) of the Act. Recently, the Chennai Bench of th…

Oetiker India P.Ltd, Mumbai vs. DCIT 13(1)(1), Mumbai

ITA 2019/MUM/2016[2011-12]Status: DisposedITAT Mumbai25 Aug 2023AY 2011-12
For Appellant: Shri Ketan VedFor Respondent: Shri Samuel Pitta
Section 143(3)Section 144C(13)Section 144C(5)Section 92C

…d loss is not in the nature of contingent liability and is allowable as deduction under Section 37 of the Act in terms of the judgment of the Hon’ble Supreme Court in the case of Commissioner of Income Tax, Delhi Vs. Woodward Governor India Pvt. Ltd. : [2009] 312 ITR 254 (SC), wherein it has been held as under: “15. For the reasons given hereinabove, we hold that, in the present case, the "loss" suffered by the assessee on account of the exchange difference as on the date of the balance sheet is an item of expenditure under section 37(1) of the 1961 Act. 16. xx xx 17. xx xx 18. AS-11 deals with giving of accounti…

DCIT, Central Circle-1, New Delhi vs. Spicejet Limited, Gurgaon

ITA 2183/DEL/2022[2018-19]Status: DisposedITAT Delhi23 Aug 2023AY 2018-19

Bench: Sh. G.S.Pannu, Hon’Ble & Sh. Anubhav Sharma

Section 143(3)Section 37(1)Section 43A

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI (DELHI BENCH ‘D’ : NEW DELHI) BEFORE SH. G.S.PANNU, HON’BLE PRESIDENT AND SH. ANUBHAV SHARMA, JUDICIAL MEMBER ITA No. 1802 & 1803/Del/2022 (Assessment Year : 2017-18 & 2018-19) M/s. Spicejet Limited, Vs. Deputy Commissioner of Income 319, Udhyog Vihar, Tax, Phase-IV Central Circle-1, Gurgaon-122016, New Delhi Haryana PAN : AACCR1459F (APPELLANT) (RESPONDENT) ITA No. 2182 & 2183/Del/2022 (Assessment Year : 2017-18 & 2018- 19) Deputy Commissioner of Vs. M/s. Spicejet Limited, Income Tax, 319, Udhyog Vihar, Central Circle-1, Phase-IV New Delhi Gurgaon-122016, Har…

DCIT, Central Circle-01, New Delhi vs. Spicejet Limited, Gurgaon

ITA 2182/DEL/2022[2017-18]Status: DisposedITAT Delhi23 Aug 2023AY 2017-18

Bench: Sh. G.S.Pannu, Hon’Ble & Sh. Anubhav Sharma

Section 143(3)Section 37(1)Section 43A

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI (DELHI BENCH ‘D’ : NEW DELHI) BEFORE SH. G.S.PANNU, HON’BLE PRESIDENT AND SH. ANUBHAV SHARMA, JUDICIAL MEMBER ITA No. 1802 & 1803/Del/2022 (Assessment Year : 2017-18 & 2018-19) M/s. Spicejet Limited, Vs. Deputy Commissioner of Income 319, Udhyog Vihar, Tax, Phase-IV Central Circle-1, Gurgaon-122016, New Delhi Haryana PAN : AACCR1459F (APPELLANT) (RESPONDENT) ITA No. 2182 & 2183/Del/2022 (Assessment Year : 2017-18 & 2018- 19) Deputy Commissioner of Vs. M/s. Spicejet Limited, Income Tax, 319, Udhyog Vihar, Central Circle-1, Phase-IV New Delhi Gurgaon-122016, Har…

Spicejet Ltd, Gurgaon vs. DCIT, Central Circle-1, New Delhi

ITA 1803/DEL/2022[2018-19]Status: DisposedITAT Delhi23 Aug 2023AY 2018-19

Bench: Sh. G.S.Pannu, Hon’Ble & Sh. Anubhav Sharma

Section 143(3)Section 37(1)Section 43A

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI (DELHI BENCH ‘D’ : NEW DELHI) BEFORE SH. G.S.PANNU, HON’BLE PRESIDENT AND SH. ANUBHAV SHARMA, JUDICIAL MEMBER ITA No. 1802 & 1803/Del/2022 (Assessment Year : 2017-18 & 2018-19) M/s. Spicejet Limited, Vs. Deputy Commissioner of Income 319, Udhyog Vihar, Tax, Phase-IV Central Circle-1, Gurgaon-122016, New Delhi Haryana PAN : AACCR1459F (APPELLANT) (RESPONDENT) ITA No. 2182 & 2183/Del/2022 (Assessment Year : 2017-18 & 2018- 19) Deputy Commissioner of Vs. M/s. Spicejet Limited, Income Tax, 319, Udhyog Vihar, Central Circle-1, Phase-IV New Delhi Gurgaon-122016, Har…

Spicejet Ltd, Gurgaon vs. DCIT, Central Circle-1, New Delhi

ITA 1802/DEL/2022[2017-18]Status: DisposedITAT Delhi23 Aug 2023AY 2017-18

Bench: Sh. G.S.Pannu, Hon’Ble & Sh. Anubhav Sharma

Section 143(3)Section 37(1)Section 43A

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI (DELHI BENCH ‘D’ : NEW DELHI) BEFORE SH. G.S.PANNU, HON’BLE PRESIDENT AND SH. ANUBHAV SHARMA, JUDICIAL MEMBER ITA No. 1802 & 1803/Del/2022 (Assessment Year : 2017-18 & 2018-19) M/s. Spicejet Limited, Vs. Deputy Commissioner of Income 319, Udhyog Vihar, Tax, Phase-IV Central Circle-1, Gurgaon-122016, New Delhi Haryana PAN : AACCR1459F (APPELLANT) (RESPONDENT) ITA No. 2182 & 2183/Del/2022 (Assessment Year : 2017-18 & 2018- 19) Deputy Commissioner of Vs. M/s. Spicejet Limited, Income Tax, 319, Udhyog Vihar, Central Circle-1, Phase-IV New Delhi Gurgaon-122016, Har…

Classic Citi Investment Pvt.Ltd, Pune vs. Pr. Commissioner of Income Tax -1, Pune

In the result, the appeal is dismissed

ITA 1317/PUN/2017[2012-13]Status: DisposedITAT Pune22 Aug 2023AY 2012-13

Bench: Shri R.S. Syal & Shri S.S.Viswanethra Raviassessment Year : 2012-13

Section 143(3)Section 263

…ect of such loan amounting to Rs.6.23 crore was claimed as deduction. The same could not have been allowed as deduction in terms of the judgment of Hon’ble Supreme Court in CIT Vs. Woodward Governor India Pvt. 3 Classic Citi Investment Pvt. Ltd. Ltd.(2009) 312 ITR 254 (SC). The AO, without conducting any enquiry on this issue, finalized the assessment u/s.143(3) and eventually allowed the deduction. In view of the fact that such foreign exchange fluctuation loss is not deductible as it pertains to loans taken for capital purposes, the AO by allowing deduction for this sum, passed an erroneous order which was p…

Leariningmate Solutions Private Limited, Mumbai vs. Ld Principle Commissioner of Income Tax-2, Mumbai

ITA 1696/MUM/2023[2018-2019]Status: DisposedITAT Mumbai31 Jul 2023AY 2018-2019
For Appellant: Shri Karthik NatarajanFor Respondent: MS N. V. Nadkarni
Section 143Section 143(1)Section 143(3)Section 263Section 263(1)Section 37(1)

…IN THE INCOME TAX APPELLATE TRIBUNAL "A" BENCH, MUMBAI SHRI OM PRAKASH KANT, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY, JUDICIAL MEMBER LearningMate Solutions Private Limited, Levels 7 to 10, Techno Park, 74/II, “C”, Cross Road, MIDC, Marol Industrial [PAN: AAACL9067F) …………… Appellant Vs Principal Commissioner of Income Tax, Mumbai - 2 Room No. 344, 3rd Floor, Aayakar Bhavan, Maharishi Karve Road, Respondent ……………. Mumbai - 400020 Appearance For the Appellant/Assessee : Shri Karthik Natarajan For the Respondent/Department : MS N. V. Nadkarni Date Conclusion of hearing : 25.07.2023 Pronouncement of order : 31.07.2023…

DDIT (It)-2(1), Mumbai vs. Standard Chartered Bank, Mumbai

Accordingly, Ground No. 11 raised by the Revenue is dismissed

ITA 884/MUM/2003[1993-94]Status: DisposedITAT Mumbai27 Jul 2023AY 1993-94
For Appellant: Shri P. J. Pardiwala, Sr. AdvocateFor Respondent: Shri Shri Soumendu Kumar Dash
Section 143(3)Section 15Section 37(2)Section 46Section 58B

…refore, so long as that stage has not been reached the loss can only be notion and actual or real. However, in a subsequent judgment the Hon’ble Supreme Court has, in the case of Commissioner of Income Tax, Delhi Vs. Woodward Governor India Pvt. Ltd. : [2009] 312 ITR 254 (SC), held as under: “15. For the reasons given hereinabove, we hold that, in the present case, the "loss" suffered by the assessee on account of the exchange difference as on the date of the balance sheet is an item of expenditure under section 37(1) of the 1961 Act. 16. xx xx 17. xx xx 18. AS-11 deals with giving of accounting treatment for the…

ACIT, Circle-6, Jaipur vs. Spytech Buildcon Pvt. Ltd., Jaipur

In the result, appeal of the revenue is dismissed

ITA 274/JPR/2023[2018-19]Status: DisposedITAT Jaipur26 Jul 2023AY 2018-19

Bench: SHRI SANDEEP GOSAIN (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Sh. Rajeev Sogani (CA)For Respondent: Sh. A. S. Nehra (Addl. CIT)
Section 142(1)Section 143(2)Section 143(3)

…profit. Further, the AO has not disturbed the practice of the assessee of crediting the P&L account with provision of losses which has resulted in lop sided results. The Hon'ble Supreme Court in the cases of CIT v. M/s. Woodward Governor India P. Ltd. [2009] 312 ITR 254 (SC) and CIT v. Realest Builders & Services Ltd [2008] 170 TAXMAN 218 (SC) had emphasised the importance of method of accounting regularly employed by the taxpayer. The Supreme Court in the case of Realest Builders & Services Ltd. had held that the tax department needs to provide facts and figures that the impugned method of accounting adopted by…

Sabre Travel Network (India) P.Ltd, Mumbai vs. DCIT 6(1)(1), Mumbai

In the result, the appeal of the assessee is partly allowed

ITA 1056/MUM/2017[2008-09]Status: DisposedITAT Mumbai25 Jul 2023AY 2008-09

Bench: Vikas Awasthy () & Ms. Padmavathy S. ()

Section 143(3)Section 144C(13)Section 234BSection 234CSection 271(1)Section 92C

…he liability were reflected as a FE liability in the annual accounts, that the approval was given by the RBI for receiving the ECB loan, that the loan was taken for working capital requirements. He relied upon the cases of Woodward Governer India Private Ltd.(312 ITR 254) Oil and Natural Gas Corporation Ltd. (322 ITR 180). The DR left the issue to the discretion of the Bench. 5.2.We have heard the rival submissions and perused the material before us. We find that the AO on one hand would tax gain on FE earnings but would not allow loss arising on FE loss. In our opinion ,the stand taken by the AO is not justified…

DCIT, Circle-5(2), New Delhi vs. Centum Learning Ltd., New Delhi

In the result, the appeal of the revenue is partly allowed and cross objection of assessee are allowed for statistical purposes

ITA 6236/DEL/2019[2011-12]Status: DisposedITAT Delhi18 Jul 2023AY 2011-12

Bench: Shri Chandra Mohan Garg & Shri Pradip Kumar Kediaassessment Year: 2011-12 The Dcit, Circle-5(2), New Delhi M/S. Centum Learning Ltd., 110002 127, Neel Gagan, Mandi Road, Vs. Sultanpur, Mehrauli, New Delhi 110030 Pan Aadcb 3842 R

For Appellant: Shri Anil Bhalla, CA
Section 14A

…010-11 & 2012-13 wherein the Assessing Officer accepted identical claim of assessee and no disallowance was made therein. The conclusion of ld. CIT(A) also gets supports from the judgment of Hon’ble Supreme Court in the case of Woodward Governor India P. Ltd. 312 ITR 254 (SC). Accordingly, we are unable to see any valid reason to interfere with the findings of the ld. CIT(A) and consequently, ground no. 3 of revenue is dismissed. Ground no. 4 of Revenue 10. The ld. Senior DR submitted that the Ld. CIT(A) has erred on facts and in law in allowing the production training expenses of Rs. 5,15,75,800/- despite the fa…

JCIT, Special Range, Panaji vs. M/S Wallace Pharmaceuticals Pvt. Ltd, Panaji

ITA 290/PAN/2019[2014-15]Status: DisposedITAT Panaji18 Jul 2023AY 2014-15

Bench: Shri Satbeer Singh Godara & Shri Inturi Rama Rao

For Appellant: Shri P.R.V RaghavanFor Respondent: Shri Prabhakar Anand DJ
Section 143(3)Section 271(1)(c)Section 37(1)

…l loss arrived at does not represent any expenditure as per section 37(1) of the Act. 5. Whether on facts of the case, the CIT(A), Panaji-1 erred in relying on the decision of Hon'ble Supreme Court in the case of CIT Vs Woodward Governor India Pvt. Ltd (2009) 312 ITR 254 (SC) to state that fluctuation in the rate of exchange with respect to loans taken for revenue purpose 3 ITA.No.289 & 290/PAN./2019 was allowable as deduction u/s 37(1) in the year of fluctuation overlooking the fact that the assessee had only reworked out the difference in loan taken and loan repaid by applying the rate of exchange at the yeare…

JCIT, Special Range, Panaji vs. M/S Wallace Pharmaceuticals Pvt. Ltd, Panaji

ITA 289/PAN/2019[2009-10]Status: DisposedITAT Panaji18 Jul 2023AY 2009-10

Bench: Shri Satbeer Singh Godara & Shri Inturi Rama Rao

For Appellant: Shri P.R.V RaghavanFor Respondent: Shri Prabhakar Anand DJ
Section 143(3)Section 271(1)(c)Section 37(1)

…l loss arrived at does not represent any expenditure as per section 37(1) of the Act. 5. Whether on facts of the case, the CIT(A), Panaji-1 erred in relying on the decision of Hon'ble Supreme Court in the case of CIT Vs Woodward Governor India Pvt. Ltd (2009) 312 ITR 254 (SC) to state that fluctuation in the rate of exchange with respect to loans taken for revenue purpose 3 ITA.No.289 & 290/PAN./2019 was allowable as deduction u/s 37(1) in the year of fluctuation overlooking the fact that the assessee had only reworked out the difference in loan taken and loan repaid by applying the rate of exchange at the yeare…

Usg Boral Building Products(India) Private Limited, Haryana vs. ITO Ward-27(2), New Delhi

In the result, the appeal of the assessee is partly allowed for statistical purposes

ITA 8446/DEL/2019[2015-16]Status: DisposedITAT Delhi14 Jul 2023AY 2015-16

Bench: Shri Kul Bharat & Shri M Balaganesh[Assessment Year : 2015-16] Knauf India Pvt.Ltd., Vs Ito, (Earlier Known As Usg Boral Ward-27(2), Building Products (India) Pvt.Ltd.), New Delhi. S-217, Ground Floor, Panchsheel Park, South Delhi, New Delhi-110017. Pan-Aabcl1984A Appellant Respondent Appellant By S/Shri S.K.Agarwal, Ca, Gopal Agarwal, Ca & Shubham Gupta, Ca Respondent By Shri Gurpreet Shah Singh, Sr. Dr Date Of Hearing 06.06.2023 Date Of Pronouncement 14.07.2023

Section 143(2)Section 37

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI “H” BENCH: NEW DELHI BEFORE SHRI KUL BHARAT, JUDICIAL MEMBER & SHRI M BALAGANESH, ACCOUNTANT MEMBER [Assessment Year : 2015-16] Knauf India Pvt.Ltd., vs ITO, (Earlier known as USG Boral Ward-27(2), Building Products (India) Pvt.Ltd.), New Delhi. S-217, Ground Floor, Panchsheel Park, South Delhi, New Delhi-110017. PAN-AABCL1984A APPELLANT RESPONDENT Appellant by S/Shri S.K.Agarwal, CA, Gopal Agarwal, CA & Shubham Gupta, CA Respondent by Shri Gurpreet Shah Singh, Sr. DR Date of Hearing 06.06.2023 Date of Pronouncement 14.07.2023 ORDER PER KUL BHARAT, JM : The present appe…

Tata Teleservices (Maharashtra)Ltd., Navi Mumbai vs. Pr CIT -8, Mumbai

In the result, the appeal by the assessee is allowed

ITA 1308/MUM/2021[2015-16]Status: DisposedITAT Mumbai13 Jul 2023AY 2015-16

Bench: Shri G.S. Pannu & Shri Sandeep Singh Karhail

For Appellant: Shri Hiten ChandeFor Respondent: Shri Biswanath Das
Section 253Section 263

…ectum of income for AY 2016-17. Without prejudice to grounds 1 to 5 above: 6. On the facts and in circumstances of the case and in law, the learned PCIT has erred in referring to the decision of Apex court in case of PCIT vs Woodward Governor India (P.) Ltd. (312 ITR 254) and Instruction No. 03/2010 issued by Central Board of Direct Taxes, by grossly ignoring the fact that the apex court in its judgment has stressed on adoption of a well-recognized method of accounting laid down by Institute of Chartered Accountants of India (ICAI) and consistency in the matter of compliance of such method of accounting and the A…