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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

Dusters Total Solutions Services Private Limited, Bangalore vs. Deputy Commissioner of Income Tax, Circle-2(1)(1), Bangalore

In the result appeal of the assessee is hereby allowed

ITA 653/BANG/2025[2020-21]Status: DisposedITAT Bangalore18 Dec 2025AY 2020-21

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Smt. Kavita Jha, AdvocateFor Respondent: Shri Shivanand H Kalakeri, CIT (DR)
Section 143(3)Section 80J

actual expenses incurred during the year. 32.1 The AO examined the reply submitted by the assessee. The assessee stated that it follows the mercantile system of accounting and therefore recognises income and expenditure on an accrual basis. The AO found this explanation not acceptable. The AO held that under section ... Therefore, the total amount of service could not be quantified before year-end. 35.1 The learned AR stated that the assessee follows the mercantile system of accounting. Under this system, income and expenditure are recognised on an accrual basis. He argued that section 145 of the Act supports this method

Dusters Total Solutions Services Private Limited, Bangalore vs. Deputy Commissioner of Income Tax, Circle-2(1)(1), Bangalore

ITA 652/BANG/2025[2018-19]Status: DisposedITAT Bangalore18 Dec 2025AY 2018-19

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Respondent: Smt. Kavita Jha, Advocate
Section 143(3)Section 80J

IN THE INCOME TAX APPELLATE TRIBUNAL 'A' BENCH, BANGALORE BEFORE SHRI WASEEM AHMED, ACCOUNTANT MEMBER AND SHRI KESHAV DUBEY, JUDICIAL

Instakart Services Private Limited, Bangalore vs. ACIT, Special Range-3, Bangalore

In the result appeal of the Revenue is hereby dismissed

ITA 544/BANG/2025[2017-18]Status: DisposedITAT Bangalore18 Dec 2025AY 2017-18

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri Ajay Vohra, Sr. Advocate and Ms. AnkitaFor Respondent: Shri Shivanad Kalakeri, CIT

lays down that such income shall, subject to the provisions of sub-section (2), be computed in accordance with either cash or mercantile system of accounting regularly employed by the assessee. Sub-section (2) of section 145 provides that the Central Government may notify in the Official Gazette from time

Instakart Services Private Limited, Bangalore vs. JCIT, Special Rang-3, Bangalore

In the result appeal of the Revenue is hereby dismissed

ITA 543/BANG/2025[2016-17]Status: DisposedITAT Bangalore18 Dec 2025AY 2016-17

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri Ajay Voh

lays down that such income shall, subject to the provisions of sub-section (2), be computed in accordance with either cash or mercantile system of accounting regularly employed by the assessee. Sub-section (2) of section 145 provides that the Central Government may notify in the Official Gazette from time

DCIT CC -1(4), Bengaluru vs. Instakart Services Pvt Ltd, Bengaluru

In the result appeal of the Revenue is hereby dismissed

ITA 531/BANG/2025[2018-19]Status: DisposedITAT Bangalore18 Dec 2025AY 2018-19

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri Ajay Voh

lays down that such income shall, subject to the provisions of sub-section (2), be computed in accordance with either cash or mercantile system of accounting regularly employed by the assessee. Sub-section (2) of section 145 provides that the Central Government may notify in the Official Gazette from time

DCIT, CC-1(4), Bengaluru vs. Instakart Services Pvt Ltd, Bengaluru

In the result appeal of the Revenue is hereby dismissed

ITA 530/BANG/2025[2017-18]Status: DisposedITAT Bangalore18 Dec 2025AY 2017-18

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri Ajay Voh

lays down that such income shall, subject to the provisions of sub-section (2), be computed in accordance with either cash or mercantile system of accounting regularly employed by the assessee. Sub-section (2) of section 145 provides that the Central Government may notify in the Official Gazette from time

Instakart Services Private Limited, Bengaluru vs. ACIT, Central Circle-1(4), Bengaluru

In the result appeal of the Revenue is hereby dismissed

ITA 496/BANG/2025[2018-19]Status: DisposedITAT Bangalore18 Dec 2025AY 2018-19

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri Ajay Voh

lays down that such income shall, subject to the provisions of sub-section (2), be computed in accordance with either cash or mercantile system of accounting regularly employed by the assessee. Sub-section (2) of section 145 provides that the Central Government may notify in the Official Gazette from time

Rupal Chemicals, Ratnagiri vs. ITO Ward 1, Ratnagiri

In the result Appeal of the assessee is allowed for statistical purposes

ITA 2588/PUN/2025[2021-22]Status: DisposedITAT Pune16 Dec 2025AY 2021-22

Bench: Dr. Manish Borad & Shri Vinay Bhamoreआयकर अपीऱ सं./Ita No.2588/Pun/2025 नििाारण वर्ा / Assessment Year: 2021-2022 Vs Ito, Ward 1, Rupal Chemicals, D/13, Midc, Lote Ratnagiri Parashuram, Taluka Khed, District Ratnagiri-415722 Maharashtra Pan-Aabfr7940R Appellant Respondent

For Appellant: Shri Ramkrishna LingsurFor Respondent: Shri Ganesh B Budruk-
Section 133(6)Section 143Section 143(2)Section 144B

year is tax neutral. 3. The Ld. A.O has erred in disallowing the commission on the ground that the appellant follows mercantile system of accounting and the commission pertained to earlier years where in fact the liability to pay commission had not crystallized at all in the earlier years

Bharti Telemedia Limited, New Delhi vs. DCIT, Circle-4(2), New Delhi

In the result, the appeals of the Assessee are allowed and appeals of the Revenue are dismissed

ITA 624/DEL/2024[2021-22]Status: DisposedITAT Delhi12 Dec 2025AY 2021-22

Bench: Shri C.N. Prasad & Shri M. Balaganesh

Section 35ASection 4

merely because a liability may be contractual or non-statutory would not make it incapable of being ascertained; where an assessee follows the mercantile system of accounting, it is not necessary that the liability must have actually been incurred during the assessment year in question to enable the assessee ... Merely because a liability may be contractual or non- statutory would not make it incapable of being ascertained. Where an Assessee follows the mercantile system of accounting it is not necessary that the liability must have actually been incurred during the Al in question to enable the Assessee to claim

DCIT, Circle 4(2), New Delhi vs. M/S Bharti Telemedia Ltd, New Delhi

In the result, the appeals of the Assessee are allowed and appeals of the Revenue are dismissed

ITA 4966/DEL/2024[2020-21]Status: DisposedITAT Delhi12 Dec 2025AY 2020-21

Bench: Shri C.N. Prasad & Shri M. Balaganesh

Section 35ASection 4

merely because a liability may be contractual or non-statutory would not make it incapable of being ascertained; where an assessee follows the mercantile system of accounting, it is not necessary that the liability must have actually been incurred during the assessment year in question to enable the assessee ... Merely because a liability may be contractual or non- statutory would not make it incapable of being ascertained. Where an Assessee follows the mercantile system of accounting it is not necessary that the liability must have actually been incurred during the Al in question to enable the Assessee to claim

Bharti Telemedia Limited, New Delhi vs. DCIT, Circle-4(2), New Delhi

In the result, the appeals of the Assessee are allowed and appeals of the Revenue are dismissed

ITA 4960/DEL/2024[2020-21]Status: DisposedITAT Delhi12 Dec 2025AY 2020-21

Bench: Shri C.N. Prasad & Shri M. Balaganesh

Section 35ASection 4

merely because a liability may be contractual or non-statutory would not make it incapable of being ascertained; where an assessee follows the mercantile system of accounting, it is not necessary that the liability must have actually been incurred during the assessment year in question to enable the assessee ... Merely because a liability may be contractual or non- statutory would not make it incapable of being ascertained. Where an Assessee follows the mercantile system of accounting it is not necessary that the liability must have actually been incurred during the Al in question to enable the Assessee to claim

DCIT, Circle 4(2), New Delhi vs. Ms Bharti Telemedia Ltd, New Delhi

In the result, the appeals of the Assessee are allowed and appeals of the Revenue are dismissed

ITA 4868/DEL/2024[2016-17]Status: DisposedITAT Delhi12 Dec 2025AY 2016-17

Bench: Shri C.N. Prasad & Shri M. Balaganesh

Section 35ASection 4

merely because a liability may be contractual or non-statutory would not make it incapable of being ascertained; where an assessee follows the mercantile system of accounting, it is not necessary that the liability must have actually been incurred during the assessment year in question to enable the assessee ... Merely because a liability may be contractual or non- statutory would not make it incapable of being ascertained. Where an Assessee follows the mercantile system of accounting it is not necessary that the liability must have actually been incurred during the Al in question to enable the Assessee to claim

Vodafone West Limited, (Formerly Known As Vodafone Essar Gujarat Limited), Ahmedabad vs. The Dy.CIT, Circle-4(1)(2), Ahmedabad

In the result, the appeal by the Revenue is partly allowed for statistical

ITA 671/AHD/2015[2010-11]Status: DisposedITAT Mumbai11 Dec 2025AY 2010-11

Bench: Shri Vikram Singh Yadavshri Sandeep Singh Karhail

For Appellant: Shri K.K. VedFor Respondent: Shri Pankaj Kumar, CIT-DR
Section 142Section 143(2)Section 143(3)Section 144CSection 144C(5)Section 45Section 47Section 48Section 50D

actual usage of its network by the customer and the services actually rendered to the customer, which is in accordance with the mercantile system of accounting, generally accepted accounting principles, accounting standards notified under the Companies Act, and the provisions of section 145 of the Act. 61. The AO, vide

The Dy CIT, Circle-4(1)(2), Ahmedabad vs. Vodafone West Limited, Ahmedabad

In the result, the appeal by the Revenue is partly allowed for statistical

ITA 1634/AHD/2015[2010-11]Status: DisposedITAT Mumbai11 Dec 2025AY 2010-11

Bench: Shri Vikram Singh Yadavshri Sandeep Singh Karhail

For Appellant: Shri K.K. VedFor Respondent: Shri Pankaj Kumar, CIT-DR
Section 142Section 143(2)Section 143(3)Section 144CSection 144C(5)Section 45Section 47Section 48Section 50D

actual usage of its network by the customer and the services actually rendered to the customer, which is in accordance with the mercantile system of accounting, generally accepted accounting principles, accounting standards notified under the Companies Act, and the provisions of section 145 of the Act. 61. The AO, vide

Rajesh Mohan Singh Hajari, Mumbai vs. ITO Ward 16(3)(1), Mumbai

In the result, ground No. 3 of assessee‟s appeal is allowed

ITA 5157/MUM/2025[2014-15]Status: DisposedITAT Mumbai10 Dec 2025AY 2014-15

Bench: Justice (Retd.) Shri C.V. Bhadang & Shri Vikram Singh Yadavassessment Year : 2014-15 Rajesh Mohan Singh Hajari, Income Tax Officer, Type 4 B/293, Ward-16(3)(1), Dr. Bam Hosp., Vs. Aayakar Bhavan, Byculla, Mumbai-400020. Mumbai-400030. Pan : Aazph4367E (Appellant) (Respondent) For Assessee : Shri Shailesh Bandi For Revenue : Shri Kavan N. Limbasiya, Sr.Dr Date Of Hearing : 03-12-2025 Date Of Pronouncement : 10-12-2025 O R D E R Per Vikram Singh Yadav, A.M : This Is An Appeal Filed By The Assessee Against The Order Of The Learned Commissioner Of Income Tax (Appeals)-National Faceless Appeal Centre (Nfac), Delhi [„Ld.Cit(A)‟], Dated 21-07-2025, Pertaining To Assessment Year (Ay) 2014-15, Wherein The Assessee Has Taken The Following Grounds Of Appeal: “1. On The Facts & Circumstances Of The Case & In Law, The Ld. Cit(A) Grossly Erred In Confirming The Action Of The Ao Of Reopening The Case Under Section 148 Of The It Act, 1961. 2. On The Facts & Circumstances Of The Case & In Law, The Ld. Cit(A) Grossly Erred In Confirming The Action Of The Ao, The Reassessment Order

For Appellant: Shri Shailesh BandiFor Respondent: Shri Kavan N. Limbasiya, Sr.DR
Section 142(1)Section 143(3)Section 147Section 148

court in the case of CIT v/s A. Krishnaswami Mudaliar 53 ITR 122 has drawn a distinction between Cash system of accounting and Mercantile system of accounting as The Hon'ble Apex Court observed as under Among Indian businessmen, as elsewhere, there are current two principle systems of bookkeeping. There

Dindayal Magasvargiya Sahakari Soot Girni Ltd, Sangli vs. Assistant Commissioner of Income Tax Circle Sangli, Circle Sangli

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

ITA 205/PUN/2025[2014-15]Status: DisposedITAT Pune09 Dec 2025AY 2014-15

Bench: Shri Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.205/Pun/2025 िनधा"रण वष" / Assessment Year : 2014-15 Dindayal Magasvargiya Vs. Acit, Circle Sangli, Sahakari Soot Girni Ltd., Sangli. At Waghwadi, Post Kameri, Tal. Walwa, Sangli- 415403. Pan : Aaaad0254E Appellant Respondent Assessee By : Shri Pramod S. Shingte Revenue By : Shri Ramnath P. Murkunde Date Of Hearing : 22.09.2025 Date Of Pronouncement : 09.12.2025 आदेश / Order Per Vinay Bhamore, Jm: This Appeal Filed By The Assessee Is Directed Against The Order Dated 05.12.2024 Passed By Ld. Cit(A)/Nfac For The Assessment Year 2014-15. 2. The Appellant Has Raised The Following Grounds Of Appeal :- “1. On The Facts & In The Circumstances Of The Case & In Law, Ld. Ao Erred In Initiating Reassessment Proceedings U/S 147 For Ay 2014-15, Being The Year Beyond 4 Years & For Which Assessment Order U/S 143(3) Has Already Been Passed, Thereby

For Appellant: Shri Pramod S. ShingteFor Respondent: Shri Ramnath P. Murkunde
Section 143(2)Section 143(3)Section 147Section 148Section 37Section 438

justified by treating the liability of accrued interest as an unascertained liability. Ld. AR further submitted that by following mercantile system of accounting the accounts were being prepared by the assessee since last many years and accordingly the interest accrued on loan was provided in the books of accounts ... under certain specific and peculiar conditions, copy of which are produced by the assessee in the paper book. Since the assessee was following mercantile system of accounting the interest on above loan was provided in the books of accounts and also claimed in the profit and loss account. The Assessing

Starkey Laboratories India Pvt. Ltd., Noida vs. DCIT Circle-24(2), New Delhi

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

ITA 3205/DEL/2023[2016-17]Status: DisposedITAT Delhi05 Dec 2025AY 2016-17

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwalstarkey Laboratories Dy. Cit, India Pvt. Ltd., Circle-24(2), C-2, Sector-7, Vs. New Delhi. Gautam Buddha Nagar-201301, Uttar Pradesh. Pan-Aakcs6072R (Appellant) (Respondent)

Section 143(3)Section 250Section 250(1)(b)Section 37(1)Section 92C

sales targets achieved by the respective parties during the relevant financial year. The provisions have been made in accordance with the mercantile system of accounting and are thus allowable as business expenditure under section 37(1) of the Income-tax Act. 1961, being incurred wholly and exclusively for the purpose ... income chargeable under the head "Profits and gains of business or profession" shall be computed in accordance with either the cash or mercantile system of accounting, regularly employed by the assessee. The appellant follows the mercantile system, under which income and expenditure are accounted for on an accrual basis, irrespective

Deputy Commissioner of Income Tax, Bengaluru vs. Flipkart India Pvt Ltd, Bengaluru

In the result, both the appeals filed by the Revenue are dismissed

ITA 1395/BANG/2025[2021-22]Status: DisposedITAT Bangalore04 Dec 2025AY 2021-22

Bench: Shri Prashant Maharishi & Shri Keshav Dubey

For Appellant: Shri Shivanand Kalakeri, CIT(DR)(ITAT), BengaluruFor Respondent: Shri Ajay Vohra, Sr. Advocate
Section 143(3)Section 37

lays down that such income shall, subject to the provisions of sub-section (2), be computed in accordance with either cash or mercantile system of accounting regularly employed by the assessee. Sub-section (2) of section 145 provides that the Central Government may notify in the Official Gazette from time

Deputy Commissioner of Income Tax, Central Circle-1(4), Bengaluru vs. Flipkart India Pvt Ltd, Bengaluru

In the result, both the appeals filed by the Revenue are dismissed

ITA 1394/BANG/2025[2020-21]Status: DisposedITAT Bangalore04 Dec 2025AY 2020-21

Bench: Shri Prashant Maharishi & Shri Keshav Dubey

For Appellant: Shri Shivanand Kalakeri, CIT(DR)(ITAT), BengaluruFor Respondent: Shri Ajay Vohra, Sr. Advocate
Section 143(3)Section 37

lays down that such income shall, subject to the provisions of sub-section (2), be computed in accordance with either cash or mercantile system of accounting regularly employed by the assessee. Sub-section (2) of section 145 provides that the Central Government may notify in the Official Gazette from time

M/S. M.P. Board of Secondary Education, Bhopal vs. The DCIT Excemption, Bhopal

Appeal is allowed

ITA 164/IND/2018[14-15]Status: DisposedITAT Indore03 Dec 2025

Bench: Shri B.M. Biyani

Section 11Section 11(1)(a)Section 143(2)Section 143(3)Section 234A

applying or accumulating the income for taking benefit of section 11(1)(a). Therefore, even in the case of an assessce following the mercantile system of accounting, there can be no doubt that for the purposes of actual application or accumulation or setting apart of income from trust property ... income-tax must be deducted for working out such surplus Income. If a notional income calculated on the basis of accrual under the mercantile system of accounting is conceived as income for the purposes under section 11(1)(a), it must be conceded that such notional income can never