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“ICDS”

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

The decision most relied on for ICDS is ICDS Ltd. v. CIT (350 ITR 527), cited in 280 judgments on BharatTax.

Leading authorities on ICDS

ICDS Ltd. v. CIT
350 ITR 527 · 2013 · Supreme Court
280
citing judgments

An assessee engaged in the business of hire purchase or leasing, being the lessor, is entitled to claim depreciation on assets leased out, even if the assets are registered in the name of the lessee and used by the lessee.

SB) in Indusind Bank Ltd. v. ADIT
19 Taxmann.com 173 · 2012 · Reported
28
citing judgments

A Special Bench decision of the Tribunal rendered prior to a Supreme Court decision is subordinate to the Supreme Court ruling.

ICDS Ltd. v. CIT
10 SCC 529 · Reported
24
citing judgments

The Supreme Court remands a matter when an assessee is deprived of the opportunity to cross-examine individuals whose statements were relied upon by the Revenue under Section 132(4) of the Income Tax Act.

ICDS Limited v. CIT (
69 Taxmann.com 317 · 2016 · High Court
24
citing judgments

In lease transactions, only the lessor is entitled to claim depreciation, regardless of whether the lease is a finance lease or an operating lease. This is because the substantial risks and rewards of ownership are not transferred to the lessee.

Manipal Finance Corporation Limited v. ACTT Circle-1 Udupi
49 Taxmann.com 353 · 2014 · High Court
19
citing judgments

This case discusses the allowability of depreciation on leased assets in finance leases, a matter that has been addressed by the Supreme Court in ICDS Ltd vs CIT.

CIT v. G Narasimhan
236 ITR 327 · 1999 · Supreme Court
15
citing judgments

Accumulated profits for the purpose of deemed dividend under section 2(22)(e) are to be computed in accordance with the Income Computation and Disclosure Standards (ICDS) rather than opening balances as per Indian GAAP. This case also touches upon the definition of 'transfer' under section 2(47).

Chamber of Tax Consultants & Anr. v. UOI
87 Taxmann.com 92 · 2017 · High Court
10
citing judgments

The Delhi High Court held that Income Computation and Disclosure Standards (ICDS) notified under Section 145(2) were ultra vires the provisions of the Income Tax Act, as they exceeded delegated legislative power. Subsequently, Section 43CB was introduced to provide statutory backing for certain ICDS provisions, such as those related to construction contracts using the percentage of completion method.

Judgments citing ICDS

Deputy Commissioner of Income Tax, Tirupur vs. Loocust Incorp, Tirupur

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

ITA 1426/CHNY/2025[2016]Status: DisposedITAT Chennai26 Nov 2025

Bench: Shri George George K & Shri Jagadish

For Appellant: Ms. Mythili, JCITFor Respondent: Shri T. Banusekar, Advocate
Section 143(2)Section 143(3)Section 2(24)(xviii)Section 250

cash incentive or duty draw back or waiver or concession or reimbursement provided under section 2(24)(xviii) of the Act. We hold the ICDS-VII is not applicable as it deals with Government grants only, but :- 5 -: not inclusive of the duty credit scrips under MEIS, which are rewards

Assistant Commissioner of Income Tax, New Delhi vs. Lurgi India International Services Private Limited, New Delhi

In the result, the appeal of Revenue is dismissed as above

ITA 5826/DEL/2024[2018-19]Status: DisposedITAT Delhi26 Nov 2025AY 2018-19

Bench: allowing carry forward of losses.”

Section 142(1)Section 37Section 79

appellant i.e., the appellant is following mercantile system of accounting, the foreign exchange loss has been accounted as per Accounting Standards 11 complied with ICDS VI and offered the foreign exchange gains for taxation whenever earned.” 6. Further, the Ld. CIT(A) also reversed the order

Shri Vardhaman Sthanakwasi Shraman, Durg vs. ITO-1(1), Bhilai

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

ITA 662/RPR/2025[2017-18]Status: HeardITAT Raipur25 Nov 2025AY 2017-18

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita No.662/Rpr/2025 "नधा"रण वष" /Assessment Year : 2017-18 Shri Vardhman Sthanakwasi Shraman Sanghiya Sharavk Sangh Trust Pravin Kumar Jain, Bandha Talab Ganjpara, Durg-491 001 (C.G.) Pan: Aalts4890F .......अपीलाथ" / Appellant बनाम / V/S. The Income Tax Officer-1(1), Bhilai (C.G.)

For Appellant: Shri Sangeet Bakliwal, CAFor Respondent: Dr. Priyanka Patel, Sr. DR
Section 143(3)Section 250Section 270ASection 44A

Normally in any real estate/construction project, estimated cost undergoes revisions as project progresses (due to escalation in material, labour, statutory levies, etc.) ICDS-III requires revised estimates of total contract cost to be used for determining stage of completion. Here, the assessee has kept the "Estimated Cost of Project" constant ... Rs14.40 crore for both years, which is unrealistic and contrary to ICDS requirements. 2. For F.Y.2015-16, they show cost incurred of Rs.8.20 crore (56.96%). Applying this percentage to consideration of Rs12.87 crore gives Rs.7.33 crore as revenue. For F.Y. 2016-17, they show cost incurred of Rs10.67 crore (74.10%), which

Apex Irrigation, Rajkot vs. The Income Tax Officer Ward-1(1)(1), Rajkot

In the result, appeal find by the assessee, is allowed

ITA 390/RJT/2025[2018-19]Status: DisposedITAT Rajkot24 Nov 2025AY 2018-19

Bench: Dr. Arjun Lal Saini

For Appellant: Shri Brijesh Parekh, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr. DR
Section 142(1)Section 143Section 143(2)Section 143(3)Section 250

return of income filed by the assessee on 26/10/2018 has been selected for scrutiny to examine the following issues, Viz: (i). Duty Drawback (ii). ICDS compliance and adjustment. The notice u/s. 143(2) of the Income Tax Page 2 of 6 Apex Irrigation Act, 1961 had been issued on 22/09/2019

Kantar Analytics India Private Limited (Formerly Known As Firefly Market Reserch India Private Limited (Successor of Analytics Quotient Service India Private Limited), Mumbai vs. Assistant Commissioner of Income Tax, Circle 1(3)(1), Mumbai

In the result the appeal filed by the assessee stands allowed

ITA 4733/MUM/2024[2020-21]Status: DisposedITAT Mumbai24 Nov 2025AY 2020-21

Bench: Smt. Beena Pillai () & Shri Omkareshwar Chidara ()

Section 143(3)Section 153Section 270ASection 92CSection 92C(1)

CASS for verification of following issues: I. II. Imports International related party transaction and services III. Loss from currency fluctuations IV. Refund claim V. ICDS compliance and adjustments VI. Foreign outward remittance 3.2 The Ld.AO noted that the assessee offers data monitoring, ad hoc consulting, statistical modelling, tools, scorecards, dashboards

DCIT 2(3)(2), Mumbai vs. Icici Bank Ltd, Mumbai

In the result, ground no. 3 of appeal of

ITA 1550/MUM/2016[2009-10]Status: DisposedITAT Mumbai21 Nov 2025AY 2009-10

Bench: Shri Pawan Singh & Shri Girish Agrawal(Physical Hearing) Icici Bank Limited, Dcit, 2(3)(2), Mumbai, Icici Bank Towers, North East Wing, Vs Aayakarbhavan, 1St Floor, Bandrakurla Complex, Mumbai – 400020. Bandra (East), Mumbai – 400051. [Pan No. Aaaci1195H] Appellant / Assessee Respondent / Revenue (Physical Hearing) Dcit, 2(3)(2), Mumbai, Icici Bank Limited Aayakar Bhavan, Vs Icici Bank Towers, North East Wing, 1St Floor, Bandrakurla Complex, Mumbai – 400020. Bandra (East), Mumbai – 400051. [Pan No. Aaaci1195H] Appellant / Assessee Respondent / Revenue

Section 10(15)Section 14ASection 254(1)Section 92CSection 92C(3)(c)

earlier assessment years. However, on appeal before ld. CIT(A), it was allowed on the basis of decision of Hon’ble Supreme Court in ICDS vs CIT 350 ITR 266 (SC) and on the basis of decision of Tribunal in assesse’s own case for earlier years ... earlier years. We find that ld. CIT(A) while allowing relief to the assessee followed the order of Hon’ble Supreme Court in ICDS vs CIT (supra). Further, similar relief was allowed in assessee’s group case in ICICI Personal Financial Services Ltd., which was later on amalgamated with

Icici Bank Ltd, Mumbai vs. DCIT 2(3)(2), Mumbai

In the result, ground no. 3 of appeal of

ITA 4418/MUM/2015[2009-10]Status: DisposedITAT Mumbai21 Nov 2025AY 2009-10

Bench: Shri Pawan Singh & Shri Girish Agrawal(Physical Hearing) Icici Bank Limited, Dcit, 2(3)(2), Mumbai, Icici Bank Towers, North East Wing, Vs Aayakarbhavan, 1St Floor, Bandrakurla Complex, Mumbai – 400020. Bandra (East), Mumbai – 400051. [Pan No. Aaaci1195H] Appellant / Assessee Respondent / Revenue (Physical Hearing) Dcit, 2(3)(2), Mumbai, Icici Bank Limited Aayakar Bhavan, Vs Icici Bank Towers, North East Wing, 1St Floor, Bandrakurla Complex, Mumbai – 400020. Bandra (East), Mumbai – 400051. [Pan No. Aaaci1195H] Appellant / Assessee Respondent / Revenue

Section 10(15)Section 14ASection 254(1)Section 92CSection 92C(3)(c)

earlier assessment years. However, on appeal before ld. CIT(A), it was allowed on the basis of decision of Hon’ble Supreme Court in ICDS vs CIT 350 ITR 266 (SC) and on the basis of decision of Tribunal in assesse’s own case for earlier years ... earlier years. We find that ld. CIT(A) while allowing relief to the assessee followed the order of Hon’ble Supreme Court in ICDS vs CIT (supra). Further, similar relief was allowed in assessee’s group case in ICICI Personal Financial Services Ltd., which was later on amalgamated with

Star Paper Mills Limited, Kolkata vs. PCIT - 2, Kolkata

In the result, the appeal of the assessee is allowed

ITA 641/KOL/2025[2018-19]Status: DisposedITAT Kolkata20 Nov 2025AY 2018-19

Bench: SHRI RAJESH KUMAR, ACCOUNTANT MEMBER SHRI PRADIP KUMAR CHOUBEY (Judicial Member)

Section 143(2)Section 143(3)Section 263Section 36(1)(vii)

regarding application of Income Computation & Disclosure Standards. The Ld. AR pointed out that, the NFAC had raised specific queries in relation to applicability of ICDS standards, and in response to which, the assessee had furnished its explanation vide letter dated 25.01.2021. He invited our attention to the Annexure ... reply and particularly to ICDS - X - ‘Provisions, Contingent Liabilities and Contingent Assets’ for which relevant disclosures were given in Tax Audit Report. The Ld. AR showed us that, the assessee had clearly stated that no increase/decrease in profit was made on account of provisions which inter alia included the provision

Asst.Commissioner of Income Tax(It)-2(1)-2, Mumbai vs. Dbs Bank Limited, Mumbai

In the result, appeal of the assessee is allowed

ITA 2430/MUM/2025[2017-18]Status: DisposedITAT Mumbai18 Nov 2025AY 2017-18

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI PRABHASH SHANKAR (Accountant Member)

Section 143(3)Section 28Section 36(1)(vii)Section 37(1)

diminution in value of securities held as available-for-sale, as per prevailing RBI guidelines, accounting standards applicable to banks, and the ICDS framework, is recognised through the profit and loss account and is allowable as deduction. 7. The ld. AO disallowed the claim after observing as under

Asst. Commissioner of Income Tax, Mumbai vs. Dbs Bank Limited, Mumbai

In the result, appeal of the assessee is allowed

ITA 2429/MUM/2025[2016-17]Status: DisposedITAT Mumbai18 Nov 2025AY 2016-17

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI PRABHASH SHANKAR (Accountant Member)

Section 143(3)Section 28Section 36(1)(vii)Section 37(1)

diminution in value of securities held as available-for-sale, as per prevailing RBI guidelines, accounting standards applicable to banks, and the ICDS framework, is recognised through the profit and loss account and is allowable as deduction. 7. The ld. AO disallowed the claim after observing as under

Rockwell Automation India Private Limited, Delhi vs. DCIT Circle-19(1), Delhi

Appeal is partly allowed for statistical purposes

ITA 3861/DEL/2024[2020-21]Status: DisposedITAT Delhi17 Nov 2025AY 2020-21

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwalrockwell Automation India Deputy Commissioner Of Private Limited, Income Tax, Circle-19(1), Registered Address: 131, Vs. Delhi. Functional Industrial Are, Patparganj, Delhi-110092 Communication Address: 131, Functional Industrial Area, Patparganj, New Delhi. Pan-Aaccr3791A (Appellant) (Respondent) Assessee By Shri Ajit Jain, Ar Department By Shri Dharm Veer Singh, Cit-Dr Date Of Hearing 19.08.2025 Date Of Pronouncement 17.11.2025 O R D E R Per Manish Agarwal, Am: This Appeal Is Filed By The Assessee Against The Final Assessment Order Passed U/S 143(3) R.W.S 144C (13) Read With Section 144B Of The Income Tax Act, 1961 (Hereinafter Referred As ‘The Act’) Dated 30.07.2024 For Assessment Year 2020-21. 2. Brief Facts Of The Case Ae That The Assessee Is A Company Engaged In The Business Of Manufacturing / Assembling Of Automation & Industrial Control Products / Systems. The Case Was Selected For Scrutiny & A Reference Was Made To The Tpo Due With Transactions With Ae’S. The Return Of Income Was Filed On Rockwell Automation India Private Limited Vs. Dcit 15.02.2021 Declaring Total Income At Rs.97,08,46,360/-. The Tpo Vide Its Order Dated 28.07.2023 Passed U/S 92Ca(3) Of The Act Has Proposed Adjustments Totaling To Rs. 26,12,44,668/-. Thereafter, The Ao Has Passed The Draft Assessment Order U/S 144C(1) Of The Act Dated 27.09.2023 Wherein The Ao Has Proposed The Additions Towards The Tp Adjustment As Per Tpo’S Order & Proposed To Assess The Total Income Of The Assessee At Rs.19,88,57,458/- & Further Proposed To Disallow Relief Claimed U/S 90/90A At Rs.1,04,60,287/-. Against The Draft Assessment Order, The Assessee Filed Objections Before The Drp.

Section 143(3)Section 144BSection 144C(1)Section 144C(10)Section 144C(13)Section 144C(8)Section 90Section 90ASection 92C

outstanding receivables. Pertaining to corporate tax matters Erroneous addition of INR 2,92,79,876 in relation to the income computation and disclosure standards (ICDS) which has already been disallowed in Income Tax Return ('ITR'). 18. On the facts and in the circumstances of case and in law, the learned ... income processed by CPC vide intimation u/s 143(1) of the Act in the impugned order which resulted into disallowance on account of ICDS adjustment. 19. On the facts and in the circumstances of case and in law, the learned AO erred in making adjustment

M/S.Ibs Software Services P. Ltd, Trivandrum vs. The DCIT, Trivandrum

ITA 601/COCH/2017[2013-14]Status: DisposedITAT Cochin13 Nov 2025AY 2013-14

Bench: SHRI INTURI RAMA RAO, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri Rajakannan, AdvocateFor Respondent: Shri Sanjit Kumar Das, CIT-DR
Section 143(3)Section 144CSection 144C(5)Section 36(1)(iii)Section 36(1)(va)Section 92C

No.9 to 11 raised by the Assessee are dismissed. 15. Before parting we would like to observe that The Income Computation and Disclosure Standards (ICDS) on which reliance was placed by the Revenue were notified by the Government of India to be effective from April 1, 2015 vide Notification

Wheatons Design Private Limited, Jaipur vs. ACIT / DCIT, Circle -6, Jaipur

In the result, appeal of the assessee is allowed

ITA 781/JPR/2025[2014-15]Status: DisposedITAT Jaipur12 Nov 2025AY 2014-15

Bench: The Due Date Of Hearing.”

For Appellant: Shri P.C. Parwal, C.AFor Respondent: Mrs. Anita rinesh, JCIT-DR a
Section 143(3)Section 144BSection 147Section 148Section 250Section 37(1)

date. An expected loss on the construction contract should be recognised as an expense immediately in accordance with paragraph 35. Similarly Para 17 of ICDS-III relating to construction contracts read as under:- The recognition of revenue and expenses by reference to the stage of completion of a contract ... revenue, expenses and profit which can be attributed to the proportion of work completed. Thus, from the combined reading of AS-7 and ICDS-III, it can be noted that in following the percentage of completion method when contract revenue is recognized, the cost associated with it should also

Nirmithi Kendra, Gadag vs. DCIT(Exemptions), Mangalore

In the result, the appeal filed by the assessee is allowed for statistical purposes

ITA 1513/BANG/2025[2022-23]Status: DisposedITAT Bangalore12 Nov 2025AY 2022-23

Bench: Shri Laxmi Prasad Sahu & Shri Soundararajan K.Assessment Year : 2022-23

For Appellant: Shri Omkar, CAFor Respondent: Shri Subramanian S., JCIT-DR
Section 12ASection 142(1)Section 143(2)Section 43C

sundry creditors and the assessee had not submitted the requisite details and documents in order to estimate the net profit as per the ICDS-III,had Page 2 of 4 estimated the net profit at 5% as profit and gains arising from the construction activity as per section 43CB

Ocean Sparkle Limited, Hyderabad vs. DCIT., Circle-5(1), Hyderabad

ITA 744/HYD/2025[2020-21]Status: DisposedITAT Hyderabad07 Nov 2025AY 2020-21
Section 115VSection 143(3)Section 144BSection 263Section 37(1)

complete scrutiny on the ground that (i). Claim of any Other Amount Allowable as deduction in Schedule BP (ii) Imports (iii) Refund Claim; (iv). ICDS Compliance and Adjustment (v). Foreign Financial Interest (vi). Exports and (vii). Deduction from Total Income under Chapter VI-A. During the course of assessment proceedings ... Imports' and did not propose for any variation on this count. Similarly, the Assessing Officer had not proposed for any variation with respect to ICDS Compliance and Adjustment after considering the explanation of the assessee dated 13.12.2021 where the assessee has submitted that no adjustments were required to be made

Arvind Nandagopal, Chennai vs. ACIT, CC-3(1), Chennai

In the result, all appeals filed by the assessee are allowed

ITA 2274/CHNY/2024[2018-19]Status: DisposedITAT Chennai07 Nov 2025AY 2018-19
Section 131Section 132

statement made by him. ." 23. The counsel for the petitioners also placed the recent judgment of the Supreme Court in the case of ICDS Ltd. v. CIT 2020 10 SCC 529, wherein, the Apex Court has remanded back the matter on account of the assessee being deprived of cross-examination

Masilamani Nandagopal, Chennai vs. ACIT, CC-3(1), Chennai

In the result, appeals filed by the assessee(s) are allowed

ITA 2269/CHNY/2024[2018-19]Status: DisposedITAT Chennai07 Nov 2025AY 2018-19

Bench: Shri Aby T. Varkey & Shri S.R.Raghunatha

For Respondent: Mr.M. Murali, CIT
Section 131Section 132Section 132(4)

Masilamani Nandagopal :: 34 :: 23. The counsel for the petitioners also placed the recent judgment of the Supreme Court in the case of ICDS Ltd. v. CIT 2020 10 SCC 529, wherein, the Apex Court has remanded back the matter on account of the assessee being deprived of cross-examination. Therefore

Masilamani Nandagopal, Chennai vs. ACIT, CC-3(1), Chennai

In the result, appeals filed by the assessee(s) are allowed

ITA 2268/CHNY/2024[2017-18]Status: DisposedITAT Chennai07 Nov 2025AY 2017-18

Bench: Shri Aby T. Varkey & Shri S.R.Raghunatha

For Appellant: Mr.B. Ramakrishnan, CAFor Respondent: Mr.M. Murali, CIT
Section 131Section 132Section 132(4)

Masilamani Nandagopal i343: 23. The counsel for the petitioners also placed the recent judgment of the Supreme Court in the case of ICDS Ltd. v. CIT 2020 10 SCC 529, wherein, the Apex Court has remanded back the matter on account of the assessee being deprived of cross-examination. Therefore

Techno Electric & Engineering Company Ltd., Noida, Uttar Pradesh vs. P.C.I.T. - 2, Kolkata

ITA 971/KOL/2025[2020-2021]Status: DisposedITAT Kolkata04 Nov 2025AY 2020-2021

Bench: Shri George Mathan, Jm & Shri Rajesh Kumar, Am

For Appellant: Shri Soumitra Choudhury, &For Respondent: Ms. Nandini Sureka, Ars
Section 139(1)Section 143(3)Section 144BSection 14ASection 263

scrutiny for the reasons namely; (i) stock valuation (ii) Claim of any other amount allowable as deduction in Schedule BP (iii) Refund Claim (iv) ICDS Compliance and Adjustment (v) Expenses Incurred for earning exempt income. The assessment was framed by the Id. AO vide order dated 20.09.2022, passed ... income chargeable under the head profit and gains of business or profession shall be computed in accordance with the income computation and disclosure standard (ICDS) as notified by the Government. The Id. PCIT observed that the assessee's treatment of ICDS adjustment as noted in Para No.3 page 1 does

Mirae Asset Capital Markets (India) Private Limited, Mumbai vs. Income Tax Officer, Ward 4(3)(1), Mumbai

The appeal of the assessee is allowed

ITA 2099/MUM/2025[2020-21]Status: DisposedITAT Mumbai04 Nov 2025AY 2020-21

Bench: Shri Amit Shukla, Jm& Ms Padmavathy S, Am

For Appellant: Shri Pratik Poddar, & Shreyas SardesaiFor Respondent: 14.10.2025
Section 143(1)Section 143(1)(a)Section 14ASection 234CSection 250

returned income of the Appellant. Addition on account of adjustment in relation to Income Computation and Disclosure Standards ('ICDS') (Rs 5,21,93,081): 2. On facts and circumstances of the case and in law, the learned CIT(A) has erred in confirming the action of the CPC of adding ... returned income of the Appellant on account of ICDS adjustment. 3. On facts and circumstances of the case and in law, the learned CIT(A) has erred in confirming the action of the CPC of adding Rs 5,21,93,081 without appreciating that the scope of adjustment