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“mercantile system of accounting”

ICDS & AccountingSection 145Section 1451,487 judgments

The decision most relied on for mercantile system of accounting is CIT v. Woodward Governor India Pvt. Ltd. (312 ITR 254), cited in 968 judgments on BharatTax.

Leading authorities on mercantile system of accounting

CIT v. Woodward Governor India Pvt. Ltd.
312 ITR 254 · 2009 · Supreme Court
968
citing judgments

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.

CIT v. Excel Industries Ltd.
358 ITR 295 · 2013 · Supreme Court
935
citing judgments

When an income or expenditure is revenue neutral across different assessment years, where any benefit derived is offset by a corresponding liability or reversal, no additional tax liability arises, particularly concerning income recognition under the mercantile system of accounting.

Rotork Controls India Pvt. Ltd. v. CIT
314 ITR 62 · 2009 · Supreme Court
739
citing judgments

A provision for expenses, such as warranty, is a deductible liability for income tax purposes if it constitutes a present obligation arising from past events, and a reliable estimate of the amount of obligation is possible.

Kedarnath Jute Mfg. Co. Ltd. v. CIT
82 ITR 363 · 1971 · Supreme Court
654
citing judgments

Tax liability for an item of income or expenditure is determined solely by the provisions of the Income-tax Act. Entries in an assessee's books of account are not conclusive and do not govern the taxability or deductibility of an item, as the legal rights and obligations under the Act prevail.

Lalchand Bhagat Ambica Ram v. CIT
37 ITR 288 · 1959 · Supreme Court
570
citing judgments

Where an assessee maintains regular books of account, and these books are not rejected or found defective by the Assessing Officer, any cash deposits or available cash shown in the cash book, if sufficient to cover the transaction, cannot be treated as unexplained income or an addition under sections 68 or 69A.

Calcutta Co. Ltd. v. CIT
37 ITR 1 · 1959 · Supreme Court
341
citing judgments

When following the mercantile system of accounting, provisions for liabilities made on a scientific and rational basis are allowable as deductions, even if their actual quantification and discharge are deferred to a future date.

United Commercial Bank v. CIT
240 ITR 355 · 1999 · Supreme Court
314
citing judgments

Liabilities accrued on a notional basis are allowable as deductions under the mercantile system of accounting even if their exact quantification or discharge is deferred to a future date or if the demand itself is disputed.

M.M.Aqua Technologies Limited v. CIT
436 ITR 582 · 2021 · Supreme Court
308
citing judgments

Amendments to tax law that impose new obligations or change existing legal positions apply prospectively, even if stated to be "for the removal of doubts." The judgment also clarifies that deductions under Section 43B are allowed only on actual payment, overriding the mercantile system of accounting.

Judgments citing mercantile system of accounting

Bajaj Electricals Ltd, Mumbai vs. Addl CIT 2(1), Mumbai

Accordingly we remit the impugned issue back to the AO with similar directions. The grounds raised by the assessee in this regard are allowed for statistical purposes

ITA 110/MUM/2016[2010-11]Status: DisposedITAT Mumbai01 Jul 2025AY 2010-11

Bench: Hon’Ble Justice (Retd.) C V Bhadang & Ms Padmavathy S, Am

For Respondent: Shri Rakesh Ranjan-CIT-DR &
Section 115Section 14ASection 250

employees in the hands of the company. We have noticed earlier that an expense becomes deductible on the incurring of liability under the mercantile system of accounting. Although the stage of taxability of perquisite in the hands of the employee may differ from the stage of the deductibility of expense

DCIT 2(1)(1), Mumbai vs. Bajaj Electricals Ltd, Mumbai

Accordingly we remit the impugned issue back to the AO with similar directions. The grounds raised by the assessee in this regard are allowed for statistical purposes

ITA 5749/MUM/2015[2010-11]Status: DisposedITAT Mumbai01 Jul 2025AY 2010-11

Bench: Hon’Ble Justice (Retd.) C V Bhadang & Ms Padmavathy S, Am

For Respondent: Shri Rakesh Ranjan-CIT-DR &
Section 115Section 14ASection 250

employees in the hands of the company. We have noticed earlier that an expense becomes deductible on the incurring of liability under the mercantile system of accounting. Although the stage of taxability of perquisite in the hands of the employee may differ from the stage of the deductibility of expense

Bajaj Electricals Ltd, Mumbai vs. Addl CIT 2(1), Mumbai

Accordingly we remit the impugned issue back to the AO with similar directions. The grounds raised by the assessee in this regard are allowed for statistical purposes

ITA 4172/MUM/2013[2009-10]Status: DisposedITAT Mumbai01 Jul 2025AY 2009-10

Bench: Hon’Ble Justice (Retd.) C V Bhadang & Ms Padmavathy S, Am

For Respondent: Shri Rakesh Ranjan-CIT-DR &
Section 115Section 14ASection 250

employees in the hands of the company. We have noticed earlier that an expense becomes deductible on the incurring of liability under the mercantile system of accounting. Although the stage of taxability of perquisite in the hands of the employee may differ from the stage of the deductibility of expense

Evroy Infraventures Pvt. Ltd., Kanpur vs. ACIT-CC-2, Kanpur

The appeal of the assessee stands partly allowed

ITA 260/LKW/2024[2019-20]Status: DisposedITAT Lucknow30 Jun 2025AY 2019-20

Bench: Shri. Sudhanshu Srivastavaassessment Year: 2019-20 Evroy Infraventures Pvt. Ltd. V. Acit C-48, Kalyanpur Central Circle 2 Kanpur Kanpur Tan/Pan:Aadce4237F (Appellant) (Respondent) Appellant By: Shri Akshay Gupta, C.A. Respondent By: Shri Sanjeev Krishna Sharma, D.R. O R D E R This Appeal Has Been Preferred By The Assessee Against The Order Dated 26.02.2024, Passed By The Ld. Commissioner Of Income Tax (Appeal), Kanpur – 4 (Ld. Cit(A)) For Assessment Year 2019-20. 2.0 The Brief Facts Of The Case Are That A Search & Seizure Operation Under Section 132 Of The Income Tax Act, 1961 (Hereinafter Called “The Act’) Was Carried Out On 17.01.2019 In Dr. M.C. Sharma, S.P.M. Hospital & Trauma Centre Group Of Cases & Also In The Case Of The Assessee’S Firm. The Assessee Is Engaged In The Business Of Infrastructure Development & Other Related Work. The Assessee Filed Its Return Of Income For The Year Under Consideration On 27.05.2020, Declaring A Total Income Of Rs.71,940/-. During The Course Of Search & Seizure Operation

For Appellant: Shri Akshay Gupta, C.AFor Respondent: Shri Sanjeev Krishna Sharma, D.R
Section 132Section 143(3)Section 271A

given further direction that if, in the process of verification, the AO finds that some sales are not booked correctly by following the mercantile system of accounting, the same may be rectified by passing a speaking order. The Ld. A.R. submitted that it was well within the powers ... issues found out during the course of verification vis-à-vis sales not being booked rightly by the assessee by following the mercantile system of accounting. In my considered view, the ld. CIT(A) has taken a very reasonable view of the issue before him and has restored the matter

Dai-Ichi Karkaria Limited, Mumbai vs. DCIT, Circle-1(1)(1), Mumbai

In the result, ground no. 4 of the assessee is allowed

ITA 1588/MUM/2025[2017-18]Status: DisposedITAT Mumbai30 Jun 2025AY 2017-18

Bench: SHRI PAWAN SINGH (Judicial Member), SHRI PRABHASH SHANKAR (Accountant Member)

Section 115JSection 14ASection 254(1)Section 270A

required to follow accounting principle while accounting income and expenditure. Section 145 of the Income Tax Act required that assessee company to follow Mercantile System of accounting which mandates accrual of all ascertained liability. During the financial year under consideration, provision was created for lowest amount as proposed

Deputy Commssioner of Income Tax, Visakhapatnam vs. Visakhapatnam Port Authority, Visakhapatnam

In the result, appeal filed by the revenue is dismissed

ITA 103/VIZ/2025[2017-18]Status: DisposedITAT Visakhapatnam27 Jun 2025AY 2017-18

Bench: Shri Ravish Sood, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपीलसं./I.T.A.No.100/Viz/2025 (निर्धारण वर्ा/ Assessment Year: 2017-18) Visakhapatnamportauthority Vs. Theasst.Cit -Circle-1(1) Administrative Office Building 4 Th Floor, Prathyakshkar Bhavan Port Area, Visakhapatnam 530001 Mvp Road, Beside Post Office Andhra Pradesh-530001. Sector-8, Mvp Colony Visakhapatnam – 530017 [Pan:Aaalv0035C] Andhrapradesh (अपीलधर्थी/Appellant) (प्रत्यर्थी/Respondent) आयकर अपीलसं./I.T.A.No.103/Viz/2025 (निर्धारण वर्ा/ Assessment Year: 2017-18) The Dy.Cit Vs. Visakhapatnamportauthority Room No. 412, 4 Th Floor Administrative Office Building Prathyakshkar Bhavan Port Area, Visakhapatnam 530035 Mvp Double Road Andhra Pradesh Opp. Rythubazar Visakhapatnam – 530014 [Pan:Aaalv0035C] Andhrapradesh (अपीलधर्थी/Appellant) (प्रत्यर्थी/Respondent) करदाता का प्रतततितित्व/ Assessee Represented By : Shri Gvn Hari, Advocate राजस्व का प्रतततितित्व/ Department Represented By : Dr.Satyasai Rath, Cit(Dr)

Section 142(1)Section 143(2)Section 143(3)Section 36(1)

year and as the nature of receipt is revenue in nature, the amount is assessable as income and does not violate the mercantile system of accounting. The lump-sum lease amount would take the characteristics of 'Income'. 3. The Ld. CIT(A), NFAC has erred in allowing the Prior period ... towards upfront premium received on lease of lands, the Ld. AR submitted that the assessee is following the mercantile system of accounting and in accordance with the Accounting Standard on leases (AS-19) issued by the ICAI upfront premium received on leasing of lands which is amortized over the period

Visakhapatnam Port Authority, Visakhapatnam vs. Assistant Commissioner of Income Tax, Circle-1(1), Visakhapatnam

In the result, appeal filed by the revenue is dismissed

ITA 100/VIZ/2025[2017-18]Status: DisposedITAT Visakhapatnam27 Jun 2025AY 2017-18

Bench: Shri Ravish Sood, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपीलसं./I.T.A.No.100/Viz/2025 (निर्धारण वर्ा/ Assessment Year: 2017-18) Visakhapatnamportauthority Vs. Theasst.Cit -Circle-1(1) Administrative Office Building 4 Th Floor, Prathyakshkar Bhavan Port Area, Visakhapatnam 530001 Mvp Road, Beside Post Office Andhra Pradesh-530001. Sector-8, Mvp Colony Visakhapatnam – 530017 [Pan:Aaalv0035C] Andhrapradesh (अपीलधर्थी/Appellant) (प्रत्यर्थी/Respondent) आयकर अपीलसं./I.T.A.No.103/Viz/2025 (निर्धारण वर्ा/ Assessment Year: 2017-18) The Dy.Cit Vs. Visakhapatnamportauthority Room No. 412, 4 Th Floor Administrative Office Building Prathyakshkar Bhavan Port Area, Visakhapatnam 530035 Mvp Double Road Andhra Pradesh Opp. Rythubazar Visakhapatnam – 530014 [Pan:Aaalv0035C] Andhrapradesh (अपीलधर्थी/Appellant) (प्रत्यर्थी/Respondent) करदाता का प्रतततितित्व/ Assessee Represented By : Shri Gvn Hari, Advocate राजस्व का प्रतततितित्व/ Department Represented By : Dr.Satyasai Rath, Cit(Dr)

Section 142(1)Section 143(2)Section 143(3)Section 36(1)

year and as the nature of receipt is revenue in nature, the amount is assessable as income and does not violate the mercantile system of accounting. The lump-sum lease amount would take the characteristics of 'Income'. 3. The Ld. CIT(A), NFAC has erred in allowing the Prior period ... towards upfront premium received on lease of lands, the Ld. AR submitted that the assessee is following the mercantile system of accounting and in accordance with the Accounting Standard on leases (AS-19) issued by the ICAI upfront premium received on leasing of lands which is amortized over the period

Peninsula Data Secure Pvt Ltd, New Delhi vs. Central Circle, 14 Delhi, New Delhi

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

ITA 1003/DEL/2025[2021-22]Status: DisposedITAT Delhi26 Jun 2025AY 2021-22
Section 154

## THE INCOME TAX APPELLATE TRIBUNAL, DELHI BENCH "E"DELHI #### BEFORESHRI SUDHIR KUMAR, JUDICIAL MEMBER AND SHRI MANISH AGARWAL, ACCOUNTANT MEMBER

Paswara Impex Ltd, New Delhi vs. DCIT, Circle-2, Meerut

The appeal is dismissed

ITA 243/DEL/2023[2015-16]Status: FixedITAT Delhi25 Jun 2025AY 2015-16

Bench: Ms. Madhumita Roy & Shri Khettra Mohan Roy

For Respondent: Ms. Harpreet Kaur Hansra, Sr
Section 143(3)Section 234ASection 44ASection 68

received a cheque of Rs.2 Crore from Nishyam Hotels Pvt. Ltd. which was booked in the assessee books of account by following proper mercantile system of accounts. 2. That this cheque was not encashed and the entry was reversed on 2.4.2015. 3. That this is not a real income ... other entry in this regard nor your goodself can suggest any different way to record this entry in the books of accounts under mercantile system of accounting. As far as the case of M/s Vimal Organics Ltd is concerned, the acts of the case are very much, different from

Morni Sarees Private Limited, Indore vs. Asst. Director of Income Tax, Income Tax Department

ITA 909/IND/2024[2020-21]Status: HeardITAT Indore24 Jun 2025AY 2020-21

Bench: Shri Bhagirath Mal Biyani & Shri Paresh M Joshi

Section 143(1)Section 154Section 246ASection 250Section 253Section 36Section 43B

Assessment Year 2020- 21 on 18.12.2020 vide Ack. No. 842860831181220 with the returned income of Rs.36,19,580/-. 2.2 That the assessee follows mercantile system of accounting and therefore had made provision for Bonus payable of Rs.7,19,000/- in his books of accounts as on 31.03.2020. 2.3 That

ACIT, Ludhiana vs. M/S Improvement Trust, Ludhiana

In the result, the appeal of the Revenue is dismissed

ITA 1027/CHANDI/2009[2005-06]Status: DisposedITAT Chandigarh24 Jun 2025AY 2005-06

Bench: Shri Rajpal Yadav & Shri Krinwant Sahayआयकर अपील सं./ Ita No. 1027/Chd/2009 "नधा"रण वष" / Assessment Year: 2005-06 The Acit, The Improvement Trust, Circle – Vi, Vs Feroze Gandhi Market, Ludhiana. Ludhiana. "थायी लेखा सं./Pan No: Aaatl4452F अपीलाथ"/Appellant ""यथ"/Respondent Assessee By : Shri Ashwani Kumar & Ms. Deepali Aggarwal,Cas Revenue By : Shri Manav Bansal, Cit, Dr Date Of Hearing : 22.05.2025 Date Of Pronouncement : 24.06.2025 Physical Hearing O R D E R

For Appellant: Shri Ashwani Kumar & Ms. Deepali Aggarwal,CAsFor Respondent: Shri Manav Bansal, CIT, DR
Section 11Section 142Section 143(2)Section 143(3)Section 145

grievance of the Revenue is that ld. CIT (Appeals) has erred in directing the AO to compute total income of the assessee on mercantile system of accounting in place of cash system of accounting adopted by the AO. The assessee is a Trust. It has filed its return of income ... appeal, ld. CIT (Appeals) has observed that consistently assessments of the assessee have been framed u/s 143(3) by adopting mercantile system of accounting, therefore, there should not be any change in the method of accounting in this year. The ld. Sr.DR except putting reliance upon the order

Dharmdeep Commodities Pvt. Ltd., Ahmedabad vs. The ACIT, Circle-1(1)(1) (Previously Circle-1(1)(2)), Ahmedabad

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

ITA 398/AHD/2023[2014-15]Status: DisposedITAT Ahmedabad24 Jun 2025AY 2014-15

Bench: Dr. B.R.R. Kumar, Vice-Shri Siddhartha Nautiyal

For Appellant: Shri Tushar Hemani, Sr. Advocate &For Respondent: Shri B.P. Srivastava, Sr DR
Section 143(3)Section 147Section 148Section 234ASection 250Section 271(1)(c)Section 37Section 68

payment is made during Dharmdeep Commodities P Ltd Vs. ACIT Asst. Year : 2014-15 - 2– next year which is in accordance with the mercantile system of accounting and ICDS-X. 3. The learned CIT(A) has erred in law and on facts of the case in confirming action

The Assistant Commissioner of Income Tax, Central Circle-1(2), Ahmedabad vs. N K Proteins Private Limited, Ahmedabad

In the result, the appeal of the Revenue is dismissed

ITA 547/AHD/2022[2015-16]Status: DisposedITAT Ahmedabad23 Jun 2025AY 2015-16

Bench: Dr. B.R.R. Kumar, Vice-Shri T.R. Senthil Kumarn.K. Proteins Pvt. Ltd., Acit, Vs. 7Th Floor, Popular House, Central Circle-1(2) Ashram Road, Ahmedabad Ahmedabad Pan : Aaacn 9377 N (Appellant) .. (Respondent) Assessee By : Shri Vartik Chokshi, Ar Revenue By: Shri V. Nandakumar, Cit-Dr & Shri Kavan Limbasiya, Sr Dr Date Of Hearing 17.03.2025 & 19.06.2025 Date Of Pronouncement 23.06.2025

For Appellant: Shri Vartik Chokshi, ARFor Respondent: Shri V. Nandakumar, CIT-DR &
Section 143(3)Section 14ASection 250Section 3Section 40A(2)(b)

deleting addition of Rs.71,460/- made on account of gain accrued through power trading, despite the fact that the assessee was following mercantile system of account. 4. On the facts and in the circumstances of the case, Ld CIT(A) erred in deleting the disallowance of prior period expenses ... recognized income of Rs. 71,460/- accrued in March 2015 hence he made addition of such amount as assessee is following mercantile system of accounting. On the other hand, assessee has stated that credit of such income earned by appellant is given by GEB in the electricity bill of subsequent

Mahakoshal Refreactories Pvt Ltd, Mumbai vs. Assistant Commissioner of Income Tax Circle 15(1), Mumbai

In the result, appeal of the assessee is allowed

ITA 930/MUM/2025[2017-18]Status: DisposedITAT Mumbai16 Jun 2025AY 2017-18

Bench: Shri Amit Shukla & Shri Girish Agrawalassessment Year: 2017-18

For Appellant: Shri. Kantilal Gugalia, CAFor Respondent: Smt. Sanyogita Nagpal, CIT DR
Section 143(3)Section 37(1)

second case, the bill was dated 31.03.2016 but was received on 21.05.2016. Ld. Assessing Officer held that since assessee follows mercantile system of accounting and the disclosures have been made of these expenses as per item 13(d) of Form 3CD, the same are not incurred during the year ... taxmann.com 286 (Cal). In this judgement, similar disallowance was made wherein ld. Assessing Officer held that the assessee having not followed the mercantile system of accounting in respect of prior period expenses debited in the profit and loss account for the current year, the same is not allowable 10 Mahakoshal

Income Tax Officer, Ward 1, Udupi, Uupi vs. Kambadakone Rytara Seva Sahakari Sangha Ltd, Udupi

ITA 1930/BANG/2024[2018-19]Status: DisposedITAT Bangalore12 Jun 2025AY 2018-19

Bench: Shri Laxmi Prasad Sahu

Section 194A(3)Section 250Section 28Section 56Section 80PSection 80P(2)(a)Section 80P(2)(d)

operative Societies Act, 1959 but also the principles of mutuality. Moreover, as verified in the audit report, the assessee society is following mercantile system of accounting. However on going through the P & L A/c, the AO found that the assessee in case of interest is following a hybrid system ... verified in the audit report, found that the assessee society is following a mercantile system of accounting. However, on going through the P & L A/c the assessee, in case of interest A/c is following a hybrid system of accounting i.e. interest income is accounted for on cash basis however

Income Tax Officer, Ward-1, Udupi vs. Kambadakone Rytara Seva Sahakari Sangha Ltd, Uppunda

ITA 1929/BANG/2024[2017-18]Status: DisposedITAT Bangalore12 Jun 2025AY 2017-18

Bench: Shri Laxmi Prasad Sahu & Shri Keshav Dubey

For Appellant: Sri Mahesh R Uppin, A.RFor Respondent: Ms. Neha Sahay, D.R
Section 194A(3)(v)Section 250Section 28Section 56Section 80PSection 80P(2)(a)Section 80P(2)(d)

operative Societies Act, 1959 but also the principles of mutuality. • Moreover, as verified in the audit report, the assessee society is following mercantile system of accounting. However on going through the P & L A/c, the AO found that the assessee in case of interest is following a hybrid system ... verified in the audit report, found that the assessee society is following a mercantile system of accounting. However, on going through the P & L A/c the assessee, in case of interest A/c is following a hybrid system of accounting i.e. interest income is accounted for on cash basis however

Sh. Rakesh Kumar Aggarwal, Jalandhar vs. The Deputy Commissioner of Income Tax, Jalandhar

The appeal stand partly allowed in terms of our above order

ITA 32/ASR/2011[2007-08]Status: DisposedITAT Amritsar10 Jun 2025AY 2007-08

Bench: Hon’Ble Shri Manoj Kumar Aggarwal, Am & Hon’Ble Shri Udayan Das Gupta, Jm आयकरअपील सं. / Ita No. 32/Asr/2011 (िनधा"रणवष" / Assessment Year: 2007-08) Shri Rakesh Kumar Aggarwal Dcit बनाम/ Vs. 310-A Guru Tegh Bahadur Nagar Range-Iii Jalandhar. Jalandhar. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aakpa-3150-H (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/Appellant By : Sh. Sandeep Vijh (Ca) –Ld.Ar ""थ"कीओरसे/Respondentby : Sh. Rajiv Wadhera (Addl. Cit) – Ld. Sr. Dr सुनवाईकीतारीख/Date Of Hearing : 23-04-2025 घोषणाकीतारीख /Date Of Pronouncement : 10-06-2025 आदेश / O R D E R Manoj Kumar Aggarwal () 1. Aforesaid Appeal By Assessee For Assessment Year (Ay) 2007-08 Arises Out Of An Order Of Ld. Commissioner Of Income Tax (Appeals), Jalandhar [Cit(A)] Dated 29-11-2010 In The Matter Of An Assessment Framed By Ld. Assessing Officer [Ao] U/S. 143(3) Of The Act On 17-12- 2009. Upon Perusal Of Records, It Could Be Seen That The Assessee’S Appeal As Well As Revenue’S Appeal For This Year Was Disposed-Off By Tribunal Vide Ita No.32/Asr/2011 & Ita No.45/Asr/2011 Common Order Dated 12-10-2012. The Appeal Of The Assessee Was Partly Allowed

For Appellant: Sh. Sandeep Vijh (CA) –Ld.ARFor Respondent: Sh. Rajiv Wadhera (Addl. CIT) – Ld. Sr. DR
Section 143(3)

contained in para-4 onwards. 5.2 On the issue of wages, Ld. CIT(A) noted that the assessee was following mercantile system of accounting. The assessee did not raise bills for payment rather the contractee made own assessment of work through engineers to make payment against the measurement. The same ... receipts of that month as against lowest rate of 9.12%. The Ld. CIT(A) has noted that the assessee was following mercantile system of accounting and correlation of expenditure with each of the contract was not available. However, the average wage rate for first nine months was 24.18% which would

Cambridge Technology Enterprises Limited, Hyderabad vs. DCIT, Circle -1, Hyderabad

ITA 388/HYD/2022[2012-13]Status: DisposedITAT Hyderabad10 Jun 2025AY 2012-13

Bench: the Dispute Resolution Panel - 1, Bangalore (for short “DRP”). The DRP, vide its order u/s 144C(5) of the Act, dt.25.10.2016 after considering the objections rejected the adjustment of Rs.7.25 crores (supra) suggested by the TPO and directed the A.O. to make an addition of Rs.10,21,789/- towards shortfall of ALP adjustment by charging 5% mark up on the reimbursement of expenses transactions. Accordingly, the A.O. vide his assessment order passed u/s 143(3) r.w.s.144C(13), dated 29.11.2016 f

For Appellant: Shri P. Murali MohanFor Respondent: Shri Narender Kumar
Section 115JSection 143(3)Section 144CSection 144C(5)Section 263Section 37(1)Section 92C

foreign exchange of Rs.2,04,70,547/- was reduced while computing the tax liability. The assessee company maintained its books of account under mercantile system of accounting and unrealized foreign exchange gain and loss computed on the last day of financial year is to be considered for taxation purpose. This ... from point no. 2.7 (foreign currency transactions and translation) of the notes to Accounts. Therefore, the unrealized/notional foreign exchange gain is taxable under mercantile system of accounting and the said amount of Rs.2,04,70,547/- was required to be brought to tax. iv. Apart from the above

DCIT Circle-1, Ranchi vs. Urmila Rcp Projects Pvt Ltd, Ranchi

In the result, appeal of the revenue and appeal of the assessee stand partly allowed for statistical purposes

ITA 146/RAN/2019[2015-16]Status: DisposedITAT Ranchi09 Jun 2025AY 2015-16

Bench: the Assessing Officer. It was the further submission that before the Id CIT(A), the assessee had provided a chart which was shown at page 19 of the order of the Id CIT(A), wherein, various details and some chart had been produced. It was the submission that the on the basis of the chart and submission of the assessee, the Id CIT(A) has in para 5.4 of his order at page 26, deleted the addition to an extent of Rs.4,16,26,731/- and has confirmed the disallowance to an extent of Rs.56,18,171/-.

For Appellant: Shri Manjit Verma, CAFor Respondent: Smt. Rinku Singh, CIT DR

such bills/details of expenses, the expenses shall not be allowed . The Assessing Officer also shall keep in mind that the assessee is following mercantile system of accounting. P a g e 3 | 4 ITA No.54/Ran/2019 Assessment Year: 2015-16 7. In the result, appeal of the revenue and appeal

Weir Minerals (India) Private Ltd, New Delhi vs. DCIT Circle-27(1), New Delhi

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

ITA 4713/DEL/2019[2012-13]Status: DisposedITAT Delhi06 Jun 2025AY 2012-13

Bench: Ms. Madhumita Roy & Shri Khettra Mohan Roy[Assessment Year 2012-13]

Section 143(3)Section 234B

accrual of an income takes place but its realization becomes impossible, such hypothetical income cannot be charged to tax. In the case of mercantile system of accounting, an accruing income can be charged to tax only when it is likely to be received under the given circumstances. In a case