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ICDS & AccountingSection 145(2)Section 145(2)865 judgments

THE BOMBAY DYEING AND MANUFACTURING COMPANY LIMITED,MUMBAI vs. INCOME TAX CENTRAL CIRCLE 2(1)(1), MUMBAI, MUMBAI

In the result, the appeal filed by the assessee is hereby allowed for statistical\npurposes

ITA 5274/MUM/2025[2018-19]Status: DisposedITAT Mumbai18 Mar 2026AY 2018-19

Bench: Shri Om Prakash Kant, Jm\Nand\Nms. Kavitha Rajagopal, Am\N\Nita No.5274/Mum/2025\N(Assessment Year: 2018-19)\Nm/S. The Bombay Dyeing And\Nmanufacturing Company Limited,\Nneville House, Jn Heredia Marg,\Nballard Estate,\Nmumbai - 400 001\Npan: Aaact2328K\Nvs.\Nnational Faceless Appeal Centre,\Ndelhi (Deputy Commissioner Of\Nincome Tax, Central Circle-2(1)(1),\Nmumbai - 400001\N(Appellant)\N(Respondent)\Nassessee By\N:\Nshri Yogesh Thar, A.R.\Nms. Sukanya Jairam, A.R &\Nshri Saurabh Surana, A.R.\Nrespondent By\N:\Nshri Leyaqat Ali Aafaqui, Sr. Ar\Ndate Of Hearing\N:\N22.12.2025\Ndate Of Pronouncement\N:\N18.03.2025\Norder\Nper Kavitha Rajagopal, J M:\Nthis Appeal Has Been Filed By The Assessee, Challenging The Order Of The Learned\Ncommissioner Of Income Tax (Appeals) [‘Ld. Cit(A)' For Short], National Faceless\Nappeal Centre (‘Nfac' For Short) Passed U/S.250 Of The Income Tax Act, 1961 (‘The Act'),\Npertaining To The Assessment Year (‘A.Y.' For Short) 2018-19.\N2.\Nthe Assessee Has Raised The Following Grounds Of Appeal:\N“1. Ground No. 1: Disallowance Of Rs. 4,65,28,171/- Under Section 14A Of The\Nact:\N1.

Section 115JSection 143(2)Section 143(3)Section 14ASection 234BSection 250Section 43C

further relied on circular No.10/2017 dated\n23.03.2017 issued by the CBDT where it has specified that Income Computation and\nDisclosure Standard (ICDS) shall apply for computation of income under the head “profits\nand gains of business or profession or income from other sources” irrespective of the\naccounting standards adopted ... companies whether accounting standards “AS” or\n“IND-AS”. The Ld. A.R. argued that since the ICDS provisions are applicable to all\ncompanies which are following mercantile system of accounting the income tax provisions\nare also equally applicable to these companies unless otherwise specified in the Act.\nThe

RELIANCE INDUSTRIAL INFRASTRUCTURE LIMITED ,MUMBAI vs. PRINCIPAL COMMISSIONER OF INCOME TAX -3, MUBMAI

In the result, the appeal filed by the assessee is hereby allowed

ITA 3751/MUM/2025[2020-21]Status: DisposedITAT Mumbai18 Mar 2026AY 2020-21

Bench: Shri Vikram Singh Yadav, Am & Ms. Kavitha Rajagopal, Jm M/S. Reliance Industrial Principal Commissioner Of Income Infrastructure Limited, Tax – 3, 5Th Floor, Nkm International House, Aayakar Bhavan, Vs. 178 Backbay Reclamation Marine Maharshi Karve Road, Lines Mumbai – 400 020 Mumbai – 400 020 Pan:Aaacr7637P (Appellant) : (Respondent)

For Respondent: Shri Umashankar Prasad, CIT-DR
Section 143(2)Section 143(3)Section 14ASection 263Section 37(1)Section 80G

during the assessment proceeding the Ld. AO had issued notice u/s 143(2) of the Act dated 29.06.2021 where the issues raised pertained to ICDS compliance and adjustment and refunds claimed. The Ld. AR further contended that the assessee duly complied with the notices and had furnished all relevant details

DCIT, CENTRAL CIRCLE 1, RAJKOT, RAJKOT vs. SHRI DEEPAK MOHANLAL PURSWANI, RAJKOT

ITA 665/RJT/2024[2022-23]Status: DisposedITAT Rajkot13 Mar 2026AY 2022-23
For Appellant: Shri Mehul Ranpura, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld. SR. DR
Section 143(3)Section 147Section 250

assessee\nalso. In our considered view, it was wholly erroneous on the part of the authorities\nbelow to apply the accounting principles of ICDS-III, as it is not applicable to the\nassessee, under consideration. We note that issue under consideration is squarely\ncovered in favour of the assessee ... money” has been received. The treatment\nof revenue recognition adopted by the learned CIT(A) is not in accordance with\nAccounting principles as per ICDS-3, which is applicable to Real Estate Developers.\nThe learned DR, therefore, stated that the income on account of undisclosed “on-\nmoney” receipt was required

DEEPAK MOHANLAL PURUSWANI,RAJKOT vs. DCIT, CC-1, RAJKOT, RAJKOT

ITA 631/RJT/2024[2022-23]Status: DisposedITAT Rajkot13 Mar 2026AY 2022-23

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinhaआयकर अपील सं/.Ita No.630 & 631/Rjt/2024 िनधा"रण वष"/ Assessment Year: (2021-2022 & 2022-23) Hybrid Hearing बनाम Shree Deepak Mohanlal Puruswani The Dcit, Cc-1 Rajkot Nr. Maa Krupa, 4- Saurashtra Kala Vs. Aaykar Bhawan “Amruta Estate”, Kendra Society, Opp. Nirmala Convent, Mg Road, Rajkot 360001, Kalawad Road, Rajkot-360001 "थायीलेखासं/.जीआइआरसं/.Pan No. : Ajvpp5139P .. (अपीलाथ"/Appellant) (""यथ"/Respondent) आयकर अपील सं/.Ita No.665/Rjt/2024 िनधा"रण वष"/ Assessment Year: (2022-23) बनाम The Dcit, Cc-1 Rajkot Shree Deepak Mohanlal Puruswani Aaykar Bhawan“Amruta Estate”, 2Nd Vs. Nr. Maa Krupa, 4- Saurashtra Kala Floor Mg Road Kendra Society, Opp. Nirmala Rajkot 360001, Gujrat Convent, Kalawad Road, Rajkot-360001 "थायीलेखासं/.जीआइआरसं/.Pan No. : Ajvpp5139P .. (अपीलाथ"/Appellant) (""यथ"/Respondent)

For Appellant: Shri Mehul Ranpura, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld. SR. DR
Section 143(3)Section 250

same is not in accordance with Accounting principles as per Page 2 of 35 ITA Nos. 630 & 631 and 665/Rjt/2024 Deepak Mohanlal Puruswani ICDS-3 applicable to Real Estate Developers and also not appreciating that the income on account of undisclosed on-money receipt was required to be assessed

DEEPAK MOHANLAL PURUSWANI,RAJKOT vs. DCIT, CC-1, RAJKOT, RAJKOT

ITA 630/RJT/2024[2021-22]Status: DisposedITAT Rajkot13 Mar 2026AY 2021-22

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinhaआयकर अपील सं/.Ita No.630 & 631/Rjt/2024 िनधा"रण वष"/ Assessment Year: (2021-2022 & 2022-23) Hybrid Hearing बनाम Shree Deepak Mohanlal Puruswani The Dcit, Cc-1 Rajkot Nr. Maa Krupa, 4- Saurashtra Kala Vs. Aaykar Bhawan “Amruta Estate”, Kendra Society, Opp. Nirmala Convent, Mg Road, Rajkot 360001, Kalawad Road, Rajkot-360001 "थायीलेखासं/.जीआइआरसं/.Pan No. : Ajvpp5139P .. (अपीलाथ"/Appellant) (""यथ"/Respondent) आयकर अपील सं/.Ita No.665/Rjt/2024 िनधा"रण वष"/ Assessment Year: (2022-23) बनाम The Dcit, Cc-1 Rajkot Shree Deepak Mohanlal Puruswani Aaykar Bhawan“Amruta Estate”, 2Nd Vs. Nr. Maa Krupa, 4- Saurashtra Kala Floor Mg Road Kendra Society, Opp. Nirmala Rajkot 360001, Gujrat Convent, Kalawad Road, Rajkot-360001 "थायीलेखासं/.जीआइआरसं/.Pan No. : Ajvpp5139P .. (अपीलाथ"/Appellant) (""यथ"/Respondent)

For Appellant: Shri Mehul Ranpura, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld. SR. DR
Section 143(3)Section 250

same is not in accordance with Accounting principles as per Page 2 of 35 ITA Nos. 630 & 631 and 665/Rjt/2024 Deepak Mohanlal Puruswani ICDS-3 applicable to Real Estate Developers and also not appreciating that the income on account of undisclosed on-money receipt was required to be assessed

DEPUTY COMMISSIONER OF INCOME TAX, SALEM vs. RAVISHANKAR, SALEM

In the result, the appeal filed by the Revenue is dismissed

ITA 2626/CHNY/2025[2019]Status: DisposedITAT Chennai13 Mar 2026

Bench: Shri S.S. Viswanethra Ravi & Ms. Padmavathy, S.आयकर अपील सं./I.T.A. No.2626/Chny/2025 िनधा"रण वष"/Assessment Year: 2019-20 The Deputy Commissioner Of Vs. Ravishankar, Income Tax, 735, Lrc Abarana Maaligai, Circle 1, Bazaar Street, Attur Tk, Salem. Salem 636 102. [Pan: Aahhr5519N] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri Shiva Srinivas, Cit ""थ" की ओर से/Respondent By : Shri D. Anand, Advocate सुनवाई की तारीख/ Date Of Hearing : 24.02.2026 घोषणा की तारीख /Date Of Pronouncement : 13.03.2026 आदेश /O R D E R Per S.S. Viswanethra Ravi: This Appeal Filed By The Revenue Is Directed Against The Order Dated 21.05.2025 Passed By The Ld. Commissioner Of Income Tax (Appeals) 18, Chennai For The Assessment Year 2019-20. 2. We Find That This Appeal Is Filed With A Delay Of 55 Days. The Dcit Circle 1, Salem Filed A Condonation Petition For The Delay Stating The Reasons. Upon Hearing Both The Parties & On Examination Of The Said Affidavit, We Find The Reasons Stated By The Dcit Are Bonafide, Which 2

For Appellant: Shri Shiva Srinivas, CITFor Respondent: Shri D. Anand, Advocate
Section 133ASection 142(1)Section 143(2)Section 143(3)Section 69ASection 69B

restoring the order of the Assessing Officer. 6. The ld. AR Shri D. Anand, Advocate submits that the valuation of stock is governed by ICDS, which mandates treatment of valuation of closing stock as business income. He submits that no excess quantity of stock was found in valuation of stock

DEEP AUTOMOTIVE,BEED vs. ITO WARD 1(5), AURANGABAD, AURANGABAD

In the result, appeal of the Assessee is allowed for statistical purposes

ITA 2832/PUN/2025[2023-2024]Status: HeardITAT Pune12 Mar 2026AY 2023-2024

Bench: Dr. Dipak P. Ripote & Shri Vinay Bhamore

For Appellant: NoneFor Respondent: Shri Shashank Ojha (virtual)
Section 143(3)Section 250Section 250(6)

income of the assessee on account of alleged undervaluation of closing stock due to non-exclusion of GST as per ICDS-II, without appreciating the fact that the purchases were accounted for net of GST and hence no income had escaped assessment. 3) That the learned Assessing Officer further erred

SIX TWENTY REALTY PVT LTD,RAJOT vs. DCIT, CC-1, RAJKOT, RAJKOT

ITA 787/RJT/2024[2020-21]Status: DisposedITAT Rajkot11 Mar 2026AY 2020-21
Section 133ASection 143(3)Section 147Section 148Section 250

assessee\nalso. In our considered view, it was wholly erroneous on the part of the authorities\nbelow to apply the accounting principles of ICDS-III, as it is not applicable to the\nassessee, under consideration. We note that issue under consideration is squarely\ncovered in favour of the assessee ... money” has been received. The treatment\nof revenue recognition adopted by the learned CIT(A) is not in accordance with\nAccounting principles as per ICDS-3, which is applicable to Real Estate Developers.\nThe learned DR, therefore, stated that the income on account of undisclosed “on-\nmoney\" receipt was required

SIX TWENTY REALTY PVT. LTD.,RAJKOT vs. DCIT, CC-1, RAJKOT, RAJKOT

ITA 786/RJT/2024[2019-20]Status: DisposedITAT Rajkot11 Mar 2026AY 2019-20
Section 133ASection 143(3)Section 147Section 148Section 250

assessee\nalso. In our considered view, it was wholly erroneous on the part of the authorities\nbelow to apply the accounting principles of ICDS-III, as it is not applicable to the\nassessee, under consideration. We note that issue under consideration is squarely\ncovered in favour of the assessee ... money” has been received. The treatment\nof revenue recognition adopted by the learned CIT(A) is not in accordance with\nAccounting principles as per ICDS-3, which is applicable to Real Estate Developers.\nThe learned DR, therefore, stated that the income on account of undisclosed “on-\nmoney\" receipt was required

SIX TWENTY REALTY PVT. LTD.,RAJKOT vs. DCIT, CC-1, RAJKOT, RAJKOT

ITA 785/RJT/2024[2018-19]Status: DisposedITAT Rajkot11 Mar 2026AY 2018-19

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinha

For Appellant: Shri Mehul Ranpura, Ld.ARFor Respondent: Shri Sanjay Punglia, Ld. CIT(DR)
Section 133ASection 143(3)Section 147Section 148Section 250

765/Rjt/2024 Six Twenty Realty Pvt. Ltd. received, ignoring that the same is not in accordance with accounting principles as per ICDS-3 applicable to Real Estate Developers and also not appreciating that the income on account of undisclosed on-money receipt was required to be assessed in the year ... year in which the on-money has been received, ignoring that the same is not in accordance with accounting principles as per ICDS-3 applicable to Real Estate Developers and also not appreciating that the income on account of undisclosed on-money receipt was required to be assessed

DCIT, CENTRAL CIRCLE-1, RAJKOT, RAJKOT vs. SIX TWENTY REALTY PRIVATE LIMITED, RAJKOT

ITA 765/RJT/2024[2019-20]Status: DisposedITAT Rajkot11 Mar 2026AY 2019-20
Section 133ASection 143(3)Section 147Section 148Section 250

assessee\nalso. In our considered view, it was wholly erroneous on the part of the authorities\nbelow to apply the accounting principles of ICDS-III, as it is not applicable to the\nassessee, under consideration. We note that issue under consideration is squarely\ncovered in favour of the assessee ... money” has been received. The treatment\nof revenue recognition adopted by the learned CIT(A) is not in accordance with\nAccounting principles as per ICDS-3, which is applicable to Real Estate Developers.\nThe learned DR, therefore, stated that the income on account of undisclosed “on-\nmoney\" receipt was required

DCIT, CENTRAL CIRCLE 1, RAJKOT, RAJKOT vs. R K DREAMLAND, RAJKOT

ITA 564/RJT/2024[2017-18]Status: DisposedITAT Rajkot11 Mar 2026AY 2017-18
For Appellant: Shri Mehul Ranpura, Ld.ARFor Respondent: Shri Sanjay Punglia, Ld. CIT(DR)
Section 143(3)Section 147Section 148Section 250

assessee\nalso. In our considered view, it was wholly erroneous on the part of the authorities\nbelow to apply the accounting principles of ICDS-III, as it is not applicable to the\nassessee, under consideration. We note that issue under consideration is squarely\ncovered in favour of the assessee ... money” has been received. The treatment\nof revenue recognition adopted by the learned CIT(A) is not in accordance with\nAccounting principles as per ICDS-3, which is applicable to Real Estate Developers.\nThe learned DR, therefore, stated that the income on account of undisclosed “on-\nmoney” receipt was required

DCIT, CENTRAL CIRCLE 1, RAJKOT, RAJKOT vs. R K DREAMLAND, RAJKOT

ITA 563/RJT/2024[2016-17]Status: DisposedITAT Rajkot11 Mar 2026AY 2016-17
Section 143(3)Section 147Section 148Section 250

assessee\nalso. In our considered view, it was wholly erroneous on the part of the authorities\nbelow to apply the accounting principles of ICDS-III, as it is not applicable to the\nassessee, under consideration. We note that issue under consideration is squarely\ncovered in favour of the assessee ... money” has been received. The treatment\nof revenue recognition adopted by the learned CIT(A) is not in accordance with\nAccounting principles as per ICDS-3, which is applicable to Real Estate Developers.\nThe learned DR, therefore, stated that the income on account of undisclosed “on-\nmoney” receipt was required

R K DREAMLAND,RAJKOT vs. DCIT, CC-1, RAJKOT, RAJKOT

ITA 560/RJT/2024[2021-22]Status: DisposedITAT Rajkot11 Mar 2026AY 2021-22
For Appellant: Shri Mehul Ranpura, Ld.ARFor Respondent: Shri Sanjay Punglia, Ld. CIT(DR)
Section 143(3)Section 147Section 148Section 250

assessee\nalso. In our considered view, it was wholly erroneous on the part of the authorities\nbelow to apply the accounting principles of ICDS-III, as it is not applicable to the\nassessee, under consideration. We note that issue under consideration is squarely\ncovered in favour of the assessee ... money” has been received. The treatment\nof revenue recognition adopted by the learned CIT(A) is not in accordance with\nAccounting principles as per ICDS-3, which is applicable to Real Estate Developers.\nThe learned DR, therefore, stated that the income on account of undisclosed “on-\nmoney” receipt was required

R K DREAMLAND,RAJKOT vs. DCIT, CC-1, RAJKOT, RAJKOT

ITA 559/RJT/2024[2020-21]Status: DisposedITAT Rajkot11 Mar 2026AY 2020-21
Section 143(3)Section 147Section 148Section 250

year in which the on-money has been received, ignoring that the same is not in accordance with accounting principles as per ICDS-3 applicable to Real Estate Developers and also not appreciating that the income on account of undisclosed on-money receipt was required to be assessed ... year in which the on-money has been received, ignoring that the same is not in accordance with accounting principles as per ICDS-3 applicable to Real Estate Developers and also not appreciating that the income on account of undisclosed on-money receipt was required to be assessed

R K DREAMLAND,RAJKOT vs. DCIT, CC-1, RAJKOT, RAJKOT

ITA 558/RJT/2024[2019-20]Status: DisposedITAT Rajkot11 Mar 2026AY 2019-20
For Appellant: Shri Mehul Ranpura, Ld.ARFor Respondent: Shri Sanjay Punglia, Ld. CIT(DR)
Section 143(3)Section 147Section 148Section 250

assessee also. In our considered view, it was wholly erroneous on the part of the authorities below to apply the accounting principles of ICDS-III, as it is not applicable to the assessee, under consideration. We note that issue under consideration is squarely covered in favour of the assessee ... money” has been received. The treatment of revenue recognition adopted by the learned CIT(A) is not in accordance with Accounting principles as per ICDS-3, which is applicable to Real Estate Developers. The learned DR, therefore, stated that the income on account of undisclosed “on- money” receipt was required

R K DREAMLAND,RAJKOT vs. DCIT, CC-1, RAJKOT, RAJKOT

ITA 557/RJT/2024[2018-19]Status: DisposedITAT Rajkot11 Mar 2026AY 2018-19
For Appellant: Shri Mehul Ranpura, Ld.ARFor Respondent: Shri Sanjay Punglia, Ld. CIT(DR)
Section 143(3)Section 147Section 148Section 250

year in which the on-money has been received, ignoring that the same is not in accordance with accounting principles as per ICDS-3 applicable to Real Estate Developers and also not appreciating that the income on account of undisclosed on-money receipt was required to be assessed ... year in which the on-money has been received, ignoring that the same is not in accordance with accounting principles as per ICDS-3 applicable to Real Estate Developers and also not appreciating that the income on account of undisclosed on-money receipt was required to be assessed

RK DREAMLAND,RAJKOT vs. ACIT, CC-1, RAJKOT, RAJKOT

ITA 556/RJT/2024[2017-18]Status: DisposedITAT Rajkot11 Mar 2026AY 2017-18
Section 143(3)Section 147Section 148Section 250

assessee\nalso. In our considered view, it was wholly erroneous on the part of the authorities\nbelow to apply the accounting principles of ICDS-III, as it is not applicable to the\nassessee, under consideration. We note that issue under consideration is squarely\ncovered in favour of the assessee ... money” has been received. The treatment\nof revenue recognition adopted by the learned CIT(A) is not in accordance with\nAccounting principles as per ICDS-3, which is applicable to Real Estate Developers.\nThe learned DR, therefore, stated that the income on account of undisclosed “on-\nmoney” receipt was required

R K DREAMLAND,RAJKOT vs. ACIT, CC-1, RAJKOT, RAJOKT

ITA 555/RJT/2024[2016-17]Status: DisposedITAT Rajkot11 Mar 2026AY 2016-17
Section 143(3)Section 147Section 148Section 250

assessee\nalso. In our considered view, it was wholly erroneous on the part of the authorities\nbelow to apply the accounting principles of ICDS-III, as it is not applicable to the\nassessee, under consideration. We note that issue under consideration is squarely\ncovered in favour of the assessee ... money” has been received. The treatment\nof revenue recognition adopted by the learned CIT(A) is not in accordance with\nAccounting principles as per ICDS-3, which is applicable to Real Estate Developers.\nThe learned DR, therefore, stated that the income on account of undisclosed “on-\nmoney” receipt was required

SURESHA CHIKKAJALA RAMAKRISHNAPPA,BANGALORE vs. DCIT, CENTRAL CIRCLE-2(3), BANGALORE

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

ITA 1292/BANG/2025[2021-22]Status: DisposedITAT Bangalore11 Mar 2026AY 2021-22

Bench: Shri Waseem Ahmed & Shri Soundararajan Kassessment Year: 2021-22

For Appellant: Shri V Srinivasan , AdvocateFor Respondent: Shri Subramanian, JCIT (DR)
Section 250Section 68

aforesaid expenditure debited to the Profit and Loss Account pertains to the projects that were under progress. 13.2 The Assessing Officer, referring to ICDS-III (Construction Contracts) and ICDS-IX (Borrowing Costs), observed that all costs relating to contract activity which are attributable to construction or development of projects ... were not related to ongoing projects. Therefore, the AO was justified in treating the same as part of work-in-progress in terms of ICDS-III and ICDS-IX. 18. We have heard the rival submissions of both the parties and perused the materials available on record. The issue relates

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