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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

Navodia Times Private Limited, Jalandhar vs. Deputy Commissioner of Income Tax Circle-1, Jalandhar

In the result, the appeal of the assessee bearing ITA 192/Asr/2022 is

ITA 192/ASR/2022[2018-19]Status: DisposedITAT Amritsar31 Jan 2023AY 2018-19

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

Section 139(1)Section 143Section 143(1)Section 234CSection 250oSection 36

liability to pay such sum was incurred by the Assessee according to the method of accounting regularly employed by it. In short, a mercantile system of accounting cannot be looked at when a deduction is claimed under this Section, making it clear that incurring of liability cannot allow ... constituted income. This is the reason why every assessee(s) [employer(s)] was entitled to deduction even prior to 1-4-1984, on mercantile system of accounting as a business expenditure by making provision in his books of accounts in that regard. In other words, if an assessee(s) [employer

Assistant Commissioner of Income Tax, Circle-IV, Pathankot vs. The Gurdaspur Central Co. Opbank Ltd, Gurdaspur

In the result, the ground no

ITA 542/ASR/2017[2013-14]Status: DisposedITAT Amritsar31 Jan 2023AY 2013-14

Bench: Dr. M. L. Meenaandsh. Anikesh Banerjee

Section 143(3)Section 250(6)Section 40Section 43D

present as per the mercantile system, but assessees used to defer payment thereof despite claiming deductions there against under the guise of mercantile system of accounting. Resultantly, irrespective of the category of liability, such deductions were regulated by law under the aegis of Section 43B, keeping in mind the peculiar

Supreme Auto 9India) Pvt, Ltd, Indore vs. ITO1 (4), Indore

In the result, the appealof assesseeis partly allowed in terms indicated above

ITA 133/IND/2020[2013-14]Status: DisposedITAT Indore30 Jan 2023AY 2013-14

Bench: Ms. Madhumita Roy & Shri B.M. Biyani

Section 143(2)Section 143(3)Section 56(2)Section 68

year. Therefore, the same was disallowed by the AO. It is also clear from the AO's order that the appellant had followed mercantile system of accounting and therefore, the expenses of previous year cannot be considered in the year under consideration. I don't find any merit to interfere

Global Consultants & Designers Pvt. Ltd., New Delhi vs. ITO Ward 11(4), New Delhi

The appeal is allowed

ITA 1424/DEL/2019[2015-16]Status: DisposedITAT Delhi25 Jan 2023AY 2015-16

Bench: Sh. Shamim Yahya & Sh. Anubhav Sharmaita No.1424/Del/2019, A.Y. 2015-16

Section 133(6)Section 143(2)Section 143(3)

immediately succeeding year. 2.3 Assessee claims that no real income accrued to the company and merely as the assessee is following mercantile system of accounting it does not result in accrual of income from interest when there is no interest in real terms and the statement of the accounts ... however observed that income of expenditure have been recognized on accrual basis and assessee is following the mercantile system of accounting in the previous year and observing that the assessee has shown interest income of Rs. 8,57,096/- and also claimed TDS of 8,57,096/- thus, he assumed

Assistant Commissioner of Income Tax, Circle, Korba vs. M/S. Dee Vee Project Ltd., Korba

In the result, appeal of the revenue is allowed/partly allowed for statistical purposes in terms of our aforesaid observations

ITA 69/RPR/2018[2014-15]Status: DisposedITAT Raipur23 Jan 2023AY 2014-15

Bench: Shri Ravish Sood & Shri G D Padmahshaliआयकर अपील सं. / Ita No.69/Rpr/2018 "नधा"रण वष" / Assessment Year : 2014-15 The Assistant Commissioner Of Income-Tax, Circle, Korba (C.G.) .......अपीलाथ" / Appellant बनाम / V/S. M/S. Dee Vee Project Ltd. First Floor, Vikas Complex, P.H. Road, Korba (C.G.) Pan : Aaecd4619B ……""यथ" / Respondent

For Appellant: Shri Prakash Chand Agrawal, CAFor Respondent: Shri G.N Singh, Sr. DR
Section 143(2)Section 143(3)Section 36(1)(va)

liability to pay such sum was incurred by the Assessee according to the method of accounting regularly employed by it. In short, a mercantile system of accounting cannot be looked at when a deduction is claimed under this Section, making it clear that incurring of liability cannot allow ... Commissioner of Income Tax, Delhi, 2021 SCC OnLine SC 575. [employer(s)] was entitled to deduction even prior to 1-4-1984, on mercantile system of accounting as a business expenditure by making provision in his books of accounts in that regard. In other words, if an assessee(s) [employer

DCIT Circle-22(2), New Delhi vs. S.T. Constructions Pvt. Ltd., New Delhi

In the result, appeal of the Revenue is 11

ITA 4149/DEL/2019[2015-16]Status: DisposedITAT Delhi20 Jan 2023AY 2015-16

Bench: Shri Anil Chaturvedi & Shri Chandra Mohan Garg

For Appellant: Shri M.P Rastogi, AdvocateFor Respondent: Shri Amaresh Singh, Sr. DR
Section 143(3)Section 37

claim lodged of Rs. 29.80 crores and credited to the P & L account were income accrued as it was following mercantile system of accounting, and disallowed the debit of Rs. 29.80 cr as "Claims/Bills submitted but not acknowledged" on the ground that the same has not been expended wholly

DCIT, Circle-24(2), New Delhi vs. Stellar Constellation Projects P.Ltd, New Delhi

ITA 5507/DEL/2017[2013-14]Status: DisposedITAT Delhi19 Jan 2023AY 2013-14

Bench: Sh. N.K.Billaiya & Sh. Anubhav Sharmaita No.5507/Del/2017, A.Y. 2013-14

Section 143(3)

principles i.e. assessee was following accounting standard 19 instead of revised accounting standard 7&9 as adopted by AO. Besides, assessee was following mercantile system of accounting in respect of accounting for revenue and expenditure, however, for the purpose of land cost, the assessee is following cash system of account

Hindustan Coca-Cola Beverages Co. P.Ltd, Gurugram vs. JCIT, Range-74, New Delhi

Accordingly, the stay application is dismissed as

ITA 3018/DEL/2022[2005-06]Status: DisposedITAT Delhi17 Jan 2023AY 2005-06

Bench: Shri Shamim Yahya & Ms. Astha Chandraआ.अ.सं/.I.T.A No.3018/Del/2022 िनधा"रणवष"/Assessment Year: 2005-06 बनाम Hindustan Coca-Cola Beverages Jcit Vs. Co. P. Ltd., Range-74, Unit No. 303-304, 3Rd Floor, New Delhi. Baani Address One, Golf Course Road, Sector-56, Gurgaon, Haryana. Pan No. Aaach3005M अपीलाथ" Appellant ""यथ"/Respondent & Stay Appl. No.413/Del/2022 िनधा"रणवष"/Assessment Year: 2005-06 बनाम Hindustan Coca-Cola Beverages Jcit Co. P. Ltd., Vs. Range-74, Unit No. 303-304, 3Rd Floor, New Delhi. Baani Address One, Golf Course Road, Sector-56, Gurgaon, Haryana. Pan No. Aaach3005M अपीलाथ" Appellant ""यथ"/Respondent

Section 143(3)Section 201Section 250(6)Section 271CSection 275(1)(c)Section 40

account of year end provisions 4 I.T.A.No.3018/Del/2022 & Stay Appl. No. 413/Del/2022 created on estimations in view. Therefore the Assessee may not of mercantile system of accounting view of amendment in Sec 40(a)(ia) vide Finance Act, 2002 . 3. No penalty can be levied u/s 271C

Sana Shah, Panipat vs. ITO, Ward-1, Panipat

Appeal stands dismissed

ITA 1702/DEL/2022[2018=-19]Status: DisposedITAT Delhi17 Jan 2023

Bench: Shri N.K. Billaiya & Shri Anubhav Sharmasana Shah, Vs. Ito, 744-745, Model Town, Ward-1, Panipat, Haryana Panipat (Appellant) (Respondent) Pan: Bopps2855R

For Appellant: Ms. Aditi S. Mann, AdvFor Respondent: Ms. Kajal Singh, Sr. DR
Section 10Section 10(37)Section 143(3)Section 145BSection 28Section 5Section 54(4)Section 56Section 56(2)(viii)

head "Profits and gains of business or profession" or "Income from other sources", shall be computed in accordance with either cash or mercantile system of accounting regularly employed by the assessee. Further, the Hon'ble Supreme Court in the case of Rama Sai v. CIT (181 ITR 400) has held

Shri Dharmendra Hirubhai Patel, Surat vs. Dy. Commissioner of Income Tax, CPC, Bangluru, Surat

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

ITA 139/SRT/2021[2018-19]Status: DisposedITAT Surat10 Jan 2023AY 2018-19

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita No.139/Srt/2021 Assessment Year: (2018-19) (Physical Court Hearing) Dharmendra Hirubhai Patel, Vs. The Dcit, Cpc, Motawada Steet, At & Po. Hazira, Bangluru. Tal: Choryasi, Surat – 394270. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Amhpp6575A (Appellant) (Respondent) Assessee By Shri Deven Kapadia, Ar Respondent By Shri Vinod Kumar, Sr. Dr Date Of Hearing 04/01/2023 10/01/2023 Date Of Pronouncement

Section 143(1)Section 2(24)Section 3Section 36Section 36(1)(va)Section 40Section 40A(2)Section 41Section 43Section 43B

liability to pay such sum was incurred by the Assessee according to the method of accounting regularly employed by it. In short, a mercantile system of accounting cannot be looked at when a deduction is claimed under this Section, making it clear that incurring of liability cannot allow ... Income Tax, Delhi, 2021 SCC On Line SC 575. 24 [employer(s)] was entitled to deduction even prior to 1-4-1984, on mercantile system of accounting as a business expenditure by making provision in his books of accounts in that regard. In other words, if an assessee(s) [employer

Addi. CIT Special Range - 6, New Delhi vs. National Fertilizers Ltd., Noida

In the result appeal of the Revenue is dismissed

ITA 7966/DEL/2019[2016-17]Status: DisposedITAT Delhi06 Jan 2023AY 2016-17

Bench: Shri Anil Chaturvedi & Shri N.K. Choudhary

For Appellant: Shri Ved Jain, AdvocateFor Respondent: Ms. Sarita Kumari, CIT-DR
Section 115JSection 143(3)Section 145Section 36(1)Section 37(1)

Assessee filed detail submissions which was not found acceptable to the A.O. A.O. was of the view that since the assessee was following mercantile system of accounting, the assessee should have offered the accrued interest to tax. He was further of the view that assessee was perusing the recovery

Shri Sureshbhai Keshubhai Kataria, at Pachiavadar, Taluka : Gondal vs. The Deputy Commissioner of Income Tax-Circle-1(2), Rajkot-Gujarat

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

ITA 375/RJT/2018[2013-14]Status: DisposedITAT Rajkot04 Jan 2023AY 2013-14

Bench: Shri Waseem Ahmed & Shri T. R. Senthil Kumar

For Appellant: NoneFor Respondent: Shri B. D. Gupta, Sr. DR
Section 143(3)Section 234ASection 274

double addition which is undesirable under the provisions of law. However, it is equally important to note that the assessee under a mercantile system of accounting has to declare income based on the concept of accrual. Be that as it may be, in the interest of justice and fair play

Maharashtra State Electricity Transmission Company Ltd., Mumbai vs. The Income Tax Officer, Ward-14(2)(3), Mumbai

In the result, the appeal of the assessee is al

ITA 990/MUM/2022[2011-12]Status: DisposedITAT Mumbai29 Dec 2022AY 2011-12

Bench: Shri Vikas Awasthy () & Shri Om Prakash Kant () Assessment Year: 2011-12 Maharashtra State Electricity Income-Tax Officer, Ward Transmission Company Ltd., 14(2)(3), Plot No. C-19 E Block, Vs. Aayakar Bhavan, Maharshi Prakashganga, Bandra-Kurla Karve Road, Complex, Bandra (East), Mumbai-400020. Mumbai-400051. Pan No. Aaecm 2936 N Appellant Respondent Assessee By : Mr. Ketan Ved, Ar Revenue By : Mr. Harishankar Lal, Dr : Date Of Hearing 15/11/2022 Date Of Pronouncement : 29/12/2022

For Appellant: Mr. Ketan Ved, ARFor Respondent: Mr. Harishankar Lal, DR
Section 148

made in the year under consideration. According to the Ld. Ld. Assessing Officer, the assessee was following Assessing Officer, the assessee was following mercantile system of accounting therefore once the income accrued mercantile system of accounting therefore once the income accrued mercantile system of accounting therefore once the income accrued ... same year ie in the AY 2011-12 as the assessee 12 as the assessee is following mercantile system of accounting. It is clear from is following mercantile system of accounting. It is clear from is following mercantile system of accounting. It is clear from the CAG report

C.U. Inspections & Certifications India Pvt. Ltd, Mumbai vs. ACIT 15(1) (2), Mumbai

In the result, all the appeals of the assessee are allowed

ITA 1633/MUM/2022[2014-15]Status: DisposedITAT Mumbai29 Dec 2022AY 2014-15

Bench: Shri Aby T. Varkey, Jm & Shri S. Rifaur Rahman, Am आयकर अपील सं/ I.T.A. No.1633/Mum/2022 (निर्धारण वर्ा / Assessment Year: 2014-15) & आयकर अपील सं/ I.T.A. No.1634/Mum/2022 (निर्धारण वर्ा / Assessment Year: 2015-16) Cu Inspections & बिधम/ Acit-15(1)(2) Certifications India Pvt. Ltd. Room No. 483, Aayakar Vs. 2201, 2205,2206, 22Nd Bhavan, Maharshi Karve Floor, 2301 To 2306 23Rd Road, Mumbai-400020. Floor, B Wing, Arihant Aura, Plot No. 13/1, Ttc, Opp Turbhe Railway Station, Thane Belapur Road, Midc Side, Turbhe Navi Mumbai-400705. स्थधयी लेखध सं./जीआइआर सं./Pan/Gir No. : Aaecc7885N (अपीलार्थी /Appellant) .. (प्रत्यर्थी / Respondent) Assessee By: Shri H. N. Motiwala Revenue By: Shri Hiren Bhatt (Sr. Ar) सुनवाई की तारीख / Date Of Hearing: 31/10/2022 घोषणा की तारीख /Date Of Pronouncement: 29/12/2022 आदेश / O R D E R Per Aby T. Varkey, Jm: These Are Appeals Preferred By The Assessee Against The Order Of The Ld. Commissioner Of Income Tax (Appeals)/(Nfac), Delhi Dated 18.05.2022 & For Ay. 2014-15 Respectively.

For Appellant: Shri H. N. MotiwalaFor Respondent: Shri Hiren Bhatt (Sr. AR)
Section 143(3)

exactly the same as its holding company. 1. The appellant has stated in the written submission that the company is following the Mercantile System of Accounting It was stated in the item no 2 of Note- 18 of A.Ys. 2014-15 & 2015-16 CU Inspections and Certifications India Financial Statement ... Real Income as enunciated by the Hon'ble Supreme Court and quoted in para-62 above If the appellant was following the Mercantile System of Accounting, it would have accounted for the income that accrued once the bill was raised for Licence Fees after the work of inspection and certification

Unilever Industries Private Ltd, Mumbai vs. ACIT Range 1(3)(1), Mumbai

In the result, we do not find any merit in this appeal, the same fails and is hereby dismissed

ITA 1015/MUM/2021[2016-17]Status: DisposedITAT Mumbai29 Dec 2022AY 2016-17

Bench: Shri Prashant Maharishi & Shri Pavan Kumar Gadaleunilever Industries Pvt Vs. Acit, Range – 1(3)(1) Ltd., Room No 504, 5 Floor, Unilever House, Bd Aayakar Bhavan, Sawant Marg, Chakala, M.K.Road, Andheri (E), Mumbai-400020 Mumbai -400099. "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aaacu0791P Appellant .. Respondent Appellant By : Ms.Jasmin Amalsadvala & Mr.Hiten Chande.Ar Respondent By : Mr. Jayant Jhaveri.Dr Date Of Hearing 15.12.2022 Date Of Pronouncement 02.01.2023 आदेश / O R D E R Per Pavan Kumar Gadale Jm: The Assessee Has Filed The Appeal Against The Order Passed U/S 143(3) & U/Sec144C(13) R.W.S 143(3A) & 143(3B) Of The Income Tax Act, 1961 Passed In Pursuance To The Directions Of The Dispute Resolution Panel (Drp) Order U/S 144C(5) Of The Act Dated 26.02.2021.The Assessee Has Raised The Following Grounds Of Appeal. Unilever Industries Pvt Ltd, Mumbai. General: 1. On The Facts & In The Circumstances Of The Case & In Law, The Learned Ao/ Assistant Commissioner Of Income-Tax (Transfer Pricing) -4(2)(2) ("Tpo") Subsequent To The Directions Issued By The Hon'Ble Drp Has Erred In Assessing The Total Income At Rs. 152,67,16,425 As Against Returned Income Of Rs. 116,80,08,280 Computed By The Appellant. 2. Parti-Transfer Pricing Adjustments: Transfer Pricing ('Tp') Adjustment On Account Of Benchmarking & Allocation Of Royalty In Respect Of Provision Of Scientific & Technical Services ('Contract R&D')

For Appellant: Ms.Jasmin Amalsadvala &For Respondent: Mr. Jayant Jhaveri.DR
Section 143(3)Section 144C(5)

Keshav Mills Ltd. supra support the case of assessee as the assessee has incurred a definite legal liability and on following the mercantile system of accounting, the discount on ESOPs has rightly been debited as expenditure in the books of accounts. We are in respectful agreement with the view taken

Deputy Commissioner of Income Tax, Central Circle-8(1), Mumbai vs. Raymond Ltd, Mumbai

In the result, appeal filed by the Revenue is dismissed

ITA 4082/MUM/2018[2012-13]Status: DisposedITAT Mumbai28 Dec 2022AY 2012-13

Bench: Shri Amit Shukla, Hon'Ble & Shri S. Rifaur Rahman, Hon'Ble

For Appellant: Shri Madhur Agrawal &For Respondent: Shri T. Shankar
Section 143(3)Section 14ASection 23Section 40A(2)(b)

calendar years 1976 to 1979, respectively. The assessee is a limited company carrying on business in textiles and maintains the accounts by mercantile system of accounting. 3. Insofar as the question No. 2 at the instance of the assessee, pertaining to assessment years 1979-80 and 1980-81 is concerned

Deputy Commissioner of Income Tax, Central Circle-8(1), Mumbai vs. Raymond Ltd, Mumbai

In the result, appeal filed by the Revenue is dismissed

ITA 4073/MUM/2018[2011-12]Status: DisposedITAT Mumbai28 Dec 2022AY 2011-12

Bench: Shri Amit Shukla, Hon'Ble & Shri S. Rifaur Rahman, Hon'Ble

For Appellant: Shri Madhur Agrawal &For Respondent: Shri T. Shankar
Section 143(3)Section 14ASection 23Section 40A(2)(b)

calendar years 1976 to 1979, respectively. The assessee is a limited company carrying on business in textiles and maintains the accounts by mercantile system of accounting. 3. Insofar as the question No. 2 at the instance of the assessee, pertaining to assessment years 1979-80 and 1980-81 is concerned

Deputy Commissioner of Income Tax, Central Circle-8(1), Mumbai vs. Raymond Ltd, Mumbai

In the result, appeal filed by the Revenue is dismissed

ITA 4072/MUM/2018[2010-11]Status: DisposedITAT Mumbai28 Dec 2022AY 2010-11

Bench: Shri Amit Shukla, Hon'Ble & Shri S. Rifaur Rahman, Hon'Ble

For Appellant: Shri Madhur Agrawal &For Respondent: Shri T. Shankar
Section 143(3)Section 14ASection 23Section 40A(2)(b)

calendar years 1976 to 1979, respectively. The assessee is a limited company carrying on business in textiles and maintains the accounts by mercantile system of accounting. 3. Insofar as the question No. 2 at the instance of the assessee, pertaining to assessment years 1979-80 and 1980-81 is concerned

Deputy Commissioner of Income Tax, Central Circle-8(1), Mumbai vs. Raymond Ltd, Mumbai

In the result, appeal filed by the Revenue is dismissed

ITA 202/MUM/2018[2009-10]Status: DisposedITAT Mumbai28 Dec 2022AY 2009-10

Bench: Shri Amit Shukla, Hon'Ble & Shri S. Rifaur Rahman, Hon'Ble

For Appellant: Shri Madhur Agrawal &For Respondent: Shri T. Shankar
Section 143(3)Section 14ASection 23Section 40A(2)(b)

calendar years 1976 to 1979, respectively. The assessee is a limited company carrying on business in textiles and maintains the accounts by mercantile system of accounting. 3. Insofar as the question No. 2 at the instance of the assessee, pertaining to assessment years 1979-80 and 1980-81 is concerned

Swiss Re Services India P.Ltd, Mumbai vs. DCIT Cir 2(3)(2), Mumbai

In the result, appeal by the assessee is allowed protanto

ITA 1898/MUM/2015[2010-11]Status: DisposedITAT Mumbai26 Dec 2022AY 2010-11

Bench: Shri Vikas Awasthy & Shri Gagan Goyalआअसं. 1898/मुं/2015 ("न.व. 2010-11) M/S. Swiss Re Services India P. Ltd. Unit 701-702, Peninsula Corporate Park Tower A, Ganpatrao Kadam Marg Lower Parel, Mumbai 400013 ...... अपीलाथ"/Appellant Pan: Aahcs5626E बनाम Vs. Dcit, Circle 2(3)(2) Room No. 552, Aayakar Bhavan ..... ""तवाद"/Respondent M K Marg, Mumbai 400020 अपीलाथ" "वारा/ Appellant By : Shri Nishant Thakkar, Adv& Shri Hiten Chande, Adv ""तवाद" "वारा/Respondent By : Shri Akhtar Ansari, Sr. Ar

For Appellant: Shri Nishant Thakkar, Adv&For Respondent: Shri Akhtar Ansari, Sr. AR
Section 143(3)

assessment. These provisions no longer required by the taxpayer during the year under review were reversed in the books of account as per mercantile system of accounting and shown as income. Therefore, on facts we do not see any justification for excluding provisions written back