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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

Brightcom Group Limited (Formerly Known As Lycos Internet Limited), Hyderabad vs. Asst. Commissioner of Income Tax, Circle-16(1), Hyderabad

In the result, the appeal filed by the assessee is allowed in terms of our observations given hereinabove

ITA 1862/HYD/2017[2013-14]Status: DisposedITAT Hyderabad03 Dec 2025AY 2013-14
Section 145Section 92BSection 92C

assessee. 2.5. Ought to have appreciated that the assessee need not to pay the tax merely because it is following the mercantile system of accounting ignoring the fact whether such book income is real income or not. 2.6. Ought to have appreciated that even in the case of mercantile system

Fuji Electric India Private Limited, Chennai vs. Deputy Commissioner of Income Tax, Corporate Circle 1(1), Chennai

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

ITA 701/CHNY/2025[2020-21]Status: DisposedITAT Chennai01 Dec 2025AY 2020-21

Bench: Shri Manu Kumar Giri & Shri S. R. Raghunatha

For Appellant: Shri. Siddhesh Chaugula, C.AFor Respondent: Shri. A R V Sreenivasan, C.I.T
Section 92C

such commissions. ‐ Actual payment is made only after the customer settles the invoice, ensuring prudent financial management. Accounting Treatment • The Appellant follows the mercantile system of accounting as per Section 145 of the Income-tax Act, 1961, under which: ‐ Expenses are recognized when incurred, not when paid. ‐ Year-end provisions

Kantaben Vajubhai Paghadal, Rajkot, Gujarat vs. ITO WD 1(2)(1), Rajkot

In the result, appeal filed by the assessee is allowed

ITA 552/RJT/2025[2016-17]Status: DisposedITAT Rajkot28 Nov 2025AY 2016-17

Bench: Dr. Arjun Lal Sainiआयकरअपीलसं./Ita No.552/Rjt/2025 "नधा"रणवष" / Assessment Year: (2016-17) (Hybrid Hearing) Kantaben Vajubhai Paghadal Vs. It-Office, New Aayakar At- Charan Samadhiyala, Bhawan, Jetpur – 360370(Gujarat) Rajkot - 360370 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Cxmpp2962D (Appellant) (Respondent)

For Appellant: Shri Sagar Shah, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr. DR
Section 10(37)Section 143(3)Section 145BSection 250Section 56

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 Smt. Rama

Deputy Commissioner of Income Tax-6, Lucknow vs. M/S. U.P. State Construction & Infrastructure Development Corporation Limited, Lucknow

ITA 617/LKW/2019[2014-15]Status: DisposedITAT Lucknow28 Nov 2025AY 2014-15

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

Section 143Section 143(3)Section 251Section 263

fact that the Ld. CIT (A) deleted the addition Rs. 1,52,02,371/-on the categorical finding that assesse has following the mercantile system of Accounting and therefore the provision of salary Rs. 1,52,02,371/- as certained liability. 5. That assesse craves leave to additions/ amendments ... Instructions issued by the Government of UP and is not an unascertained liability. The provision is actual liability and is allowable as per mercantile system of accounting followed by the Appellant. The disallowance of Rs. 1,91,54,470/- made by the AO is therefore deleted giving relief

U.P Samaj Kalyan Nirman Nigam Limited (Now Known As U.P State Construction and Infrastructure Development Corporation Ltd.), Lucknow vs. Principal Commissioner of Income Tax-2, Lucknow

ITA 67/LKW/2016[2011-12]Status: DisposedITAT Lucknow28 Nov 2025AY 2011-12

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

Section 143Section 143(3)Section 251Section 263

fact that the Ld. CIT (A) deleted the addition Rs.1,52,02,371/-on the categorical finding that assesse has following the mercantile system of Accounting and therefore the provision of salary Rs.1,52,02,371/- as certained liability. 5. That assesse craves leave to additions/ amendments in the Grounds

Amrita Prabhakar Deodhar, Andheri vs. Income Tax Assistant Commissioner, Mumbai

In the result, the appeal filed by the assessee bearing ITA No

ITA 5892/MUM/2025[2006-07]Status: DisposedITAT Mumbai28 Nov 2025AY 2006-07

Bench: Vikram Singh Yadavshri Anikesh Banerjee

For Appellant: Shri Rajesh PurohitFor Respondent: Shri Surendra Mohan (SR DR)
Section 139(1)Section 143(3)Section 194JSection 250Section 40

onwards after Mr. Nitin Barve left his service with the appellant in F.Y. 2003-04 Since the appellant was following mercantile system of accounting, it was appellant who had to establish that liability pertaining to previous year i.e., prior period expenses, was actually crystallized during instant year. However

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

critical in determining whether an expenditure relating to foreign exchange is deductible. The same are reproduced as under: • Whether the Assessee follows a mercantile system of accounting, which allows for the accrual of expenditure and revenue; • Whether the Assessee has consistently followed this system from the beginning and, if there ... factors laid down by the Apex Court in the above referred decision have been satisfied by the 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

Vijayraghavan Subramanian Iyer, Mumbai vs. Income Tax Officer 27 3 5 Mumbai, Mumbai

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

ITA 3465/MUM/2025[2014-15]Status: DisposedITAT Mumbai25 Nov 2025AY 2014-15

Bench: Shri Sandeep Gosain

Section 198Section 250

been made. 4. Whereas the revenue authorities rejected the said contentions and submitted that as per audit report, the method of accounting is mercantile system of accounting and therefore, the assessee is required to offer the income on accrual basis and if required, later on, that portion of income which ... judgment, we would not be justified in attaching any particular importance in this case to the fact that the company followed the mercantile system of account. That would not have any particular bearing in applying the principle of real income to the facts of this case….." (p. 720) The said

Valuzhathil Padmanabhan Sivadasan, Thiruvalla vs. Income Tax Officer, Ward-2, Thiruvalla

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

ITA 770/COCH/2025[2015-16]Status: DisposedITAT Cochin21 Nov 2025AY 2015-16

Bench: Shri Inturi Rama Rao, Am Assessment Year: 2015-16 Valuzhathil Padmanabhan Sivadasan .......... Appellant Valuzhathil House, Kozhuvalloor, Thiruvalla [Pan: Akaps3606C] Vs. The Income Tax Officer, Ward-2, Thiruvalla .......... Respondent Assessee By: Shri Stephen George, Ar Revenue By: Smt. Leena Lal, Sr. D.R. Date Of Hearing: 06.11.2025 Date Of Pronouncement: 21.11.2025 O R D E R This Appeal Filed By The Assessee Is Directed Against The Order Of The Commissioner Of Income Tax (Appeals)-2, Noida [Cit(A)] Dated 25.08.2025 For Assessment Year (Ay) 2015-16. 2. Brief Facts Of The Case Are That The Appellant Is A Non-Resident Indian. No Regular Return Of Income Under The Provisions Of Section 139(1) Of The Income Tax Act, 1961 (The Act) Was Filed By The Appellant. The Dcit (International Taxation) Lkn (Hereinafter Called "The Ao"), Based On The Information That The Appellant Made Term Deposits In Bank & Earned Interest Income Of Deposits, Formed An Opinion That Income Escaped Assessment To Tax. Accordingly, The 2 Valuzhathil Padmanabhan Sivadasan Ao Issued A Notice U/S. 148 Of The Act After Duly Complying The Provisions Of Section 148(A) Of The Act. In Response To The Notice U/S. 148, The Appellant Filed Return Of Income For Ay 2016-17 On 30.08.2022 Declaring Total Income Of Rs. 2,44,870/-. Against The Said Return Of Income, The Assessment Was Completed By The Ao Vide Order Dated 26.05.2023 Passed U/S. 147 R.W.S. 144C(3) Of The Act At Total Income Of Rs. 35,01,948/-. While Doing So, The Ao Brought To Tax The Income Of Salary Of Rs. 32,57,078/-.

For Appellant: Shri Stephen George, ARFor Respondent: Smt. Leena Lal, Sr. D.R
Section 139(1)Section 147Section 148Section 4(1)(a)

volition or sweet will of an individual. The profits earned which were credited in the books of account according to the mercantile system of accounting were at best "treated as having been received" which is neither "received" nor "deemed to be received" and therefore not within the purview of section

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)

income chargeable under the head profit and gain from business and profession is to be computed in accordance with either cash system or mercantile system of accounting regularly followed by the assessee. The assessee is following mercantile system of accounting and makes provision for expenses incurred during the year ... through the orders of lower authorities. We find merit on the submissions of ld. AR of the assessee that the assessee was following mercantile system of accounting regularly and making provision for expenses incurred during the year as has been claimed as at 31st March of relevant financial year

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)

income chargeable under the head profit and gain from business and profession is to be computed in accordance with either cash system or mercantile system of accounting regularly followed by the assessee. The assessee is following mercantile system of accounting and makes provision for expenses incurred during the year ... through the orders of lower authorities. We find merit on the submissions of ld. AR of the assessee that the assessee was following mercantile system of accounting regularly and making provision for expenses incurred during the year as has been claimed as at 31st March of relevant financial year

Mohammed Kutty Pudukkudi, Malappuram vs. ACIT, Central Circle-2, Kozhikode

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

ITA 774/COCH/2025[2013-14]Status: DisposedITAT Cochin19 Nov 2025AY 2013-14

Bench: Shri Inturi Rama Rao, Am & Shri Manu Kumar Giri, Jm Assessment Year: 2013-14 Mohammed Kutty Pudukkudi .......... Appellant 4/61, Pudukkudi House, Ponmundam P.O. (Via) Tirur 676106 [Pan: Afepp4646J] Vs. Acit, Central Circle-2, Kozhikode ......... Respondent Assessee By: Shri C.B.M. Warrier, Ca Revenue By: Shri Sanjit Kumar Das, Cit-Dr Date Of Hearing: 06.11.2025 Date Of Pronouncement: 19.11.2025

For Appellant: Shri C.B.M. Warrier, CAFor Respondent: Shri Sanjit Kumar Das, CIT-DR
Section 132Section 143(3)Section 153A

volition or sweet will of an individual. The profits earned which were credited in the books of account according to the mercantile system of accounting were at best "treated as having been received" which is neither "received" nor "deemed to be received" and therefore not within the purview of section

Waterworld Tourism Company Private Limited, Alappuzha vs. ITO Ward 1 & Tps, Alappuzha

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

ITA 726/COCH/2025[2018-19]Status: DisposedITAT Cochin19 Nov 2025AY 2018-19

Bench: Shri Inturi Rama Rao, Am & Shri Manu Kumar Giri, Jm Assessment Year: 2018-19 Water World Tourism Company Pvt. Ltd. .......... Appellant Room No. 18, Municipal Shopping Centre Zilla Court Ward, Opp. Boat Jetty Thathampally S.O., Alappuzha 688013 [Pan: Aabcm3387L] Vs. The Income Tax Officer, Wd-1& Tps, Alappuzha ......... Respondent Assessee By: Shri Thomas Joseph, Ca Revenue By: Shri Sanjit Kumar Das, Cit-Dr Date Of Hearing: 04.11.2025 Date Of Pronouncement: 19.11.2025

For Appellant: Shri Thomas Joseph, CAFor Respondent: Shri Sanjit Kumar Das, CIT-DR
Section 115BSection 143(3)Section 68

volition or sweet will of an individual. The profits earned which were credited in the books of account according to the mercantile system of accounting were at best "treated as having been received" which is neither "received" nor "deemed to be received" and therefore not within the purview of section

DCIT, Circle - 19(1), Delhi vs. Ptc India Ltd., Delhi

Appeal of the Revenue is dismissed

ITA 3225/DEL/2024[2018-19]Status: DisposedITAT Delhi19 Nov 2025AY 2018-19

Bench: Shri Sudhir Kumar & Shri Manish Agarwal

Section 143(3)Section 14ASection 250

surcharge may or may not be paid or recovered or may eventually be waived, is entirely irrelevant as the assessee maintains a mercantile system of accounting. Aggrieved by the aforesaid finding, the assessee filed an appeal. The CIT(Appeals) vide order dated 06.11.2009, set aside the addition made ... No.961/Del/2023 & 3225/Del/2024 "The issue involved and the submissions made by the appellant have been considered. It is undisputed that the appellant is following mercantile system of accounting: it is levying surcharge on delayed payment of bills by the consumers; the surcharge is taken as income as and when

Ptc India Limited, Delhi vs. DCIT, Circle-19(1), New Delhi

In the result, appeal of the Revenue is dismissed

ITA 961/DEL/2023[2018-19]Status: DisposedITAT Delhi19 Nov 2025AY 2018-19

Bench: Shri Sudhir Kumar & Shri Manish Agarwal[Assessment Year : 2018-19] Ptc India Ltd. Vs Dcit 2Nd Floor, Nbcc Tower, Circle-19(1), Delhi Bhikaji Cama Place, 15, R.K.Puram (Main), New Delhi-110066. Pan-Aabcp7947F Appellant Respondent [Assessment Year : 2018-19] Dcit Vs Ptc India Ltd. Circle-19(1), 2Nd Floor, Nbcc Tower, Delhi Bhikaji Cama Place, 15, R.K.Puram (Main), New Delhi-110066. Pan-Aabcp7947F Appellant Respondent Appellant By Shri Salil Kapoor, Adv. & Ms. Soumya Singh, Adv Respondent By Shri D S Sidhu, Cit Dr Date Of Hearing 25.08.2025 Date Of Pronouncement 19.11.2025

Section 143(3)Section 14ASection 250

surcharge may or may not be paid or recovered or may eventually be waived, is entirely irrelevant as the assessee maintains a mercantile system of accounting. Aggrieved by the aforesaid finding, the assessee filed an appeal. The CIT(Appeals) vide order dated 06.11.2009, set aside the addition made ... No.961/Del/2023 & 3225/Del/2024 "The issue involved and the submissions made by the appellant have been considered. It is undisputed that the appellant is following mercantile system of accounting: it is levying surcharge on delayed payment of bills by the consumers; the surcharge is taken as income as and when

Jagtar Singh Brar Prop. Jagtar Singh Sadhu Singh, Bagapurana vs. Income Tax Officer, Ward 3, Moga

In the result, the penalty imposed u/s 271(1) (c) amounting to Rs

ITA 70/ASR/2025[2015-16]Status: DisposedITAT Amritsar18 Nov 2025AY 2015-16

Bench: Sh. Udayan Dasgupta & Sh. Khettra Mohan Roy

For Appellant: Sh. Abhinav Vijh, C.A
Section 133(6)Section 145(3)Section 250Section 271(1)Section 271(1)(c)Section 44A

also applicable in the present case wherein Hon'ble High Court has held that penalty is leviable in case assessee is following Mercantile System of accounting and failed to include accrued interest in his return and also failed to show that there is no change in method of accounting

Assistant Commissioner of Income Tax, Mumbai vs. Nevales Networks Private Limited, Mumbai

In the result, the appeal of the Revenue is dismissed

ITA 4827/MUM/2025[2013-14]Status: DisposedITAT Mumbai17 Nov 2025AY 2013-14

Bench: Shri Vikram Singh Yadav & Shri Sandeep Singh Karhailassessment Year : 2013-14 Dcit, Circle-14(1)(1), M/S. Nevales Networks Pvt. Ltd., Room No. 432, 4Th Floor, The Capital, Aayakar Bhavan, Vs. Level 7, Plot-C70, M.K.Road, G Block, Mumbai-400020. Bandra Kurla Complex, Bandra (East), Mumbai-400051. Pan : Aadcn1748A (Appellant) (Respondent) Assessee By : Shri Piyush Chhajed Revenue By : Shri Leyaqat Ali Aafaqui

For Appellant: Shri Piyush ChhajedFor Respondent: Shri Leyaqat Ali Aafaqui
Section 143(3)Section 271(1)(c)

stands deleted. 10. As regards the addition of Rs. 63,91,700/-, the appellant has submitted that it maintained books of accounts on Mercantile system of accounting, it raised the Invoices for various durations ranging from one month to one year as and when the contract for services is entered ... claim that the addition of Rs. 63,91,700/- does not attract penalty provisions. It is a fact that the appellant followed mercantile system of accounting and the Advance Revenue pertaining to next year was shown as Subscription Received in advance and it cannot be thus treated or considered

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)

disallowance made by AO treating the provision made for future expenses as a contingent liability. Submission:- It is submitted that assessee is following mercantile system of accounting which is continued to be followed on year to year basis. In respect of construction contract assessee follows percentage of completion method

Ahluwalia Erectors & Fabricators Private Limited, Kota vs. DCIT/ACIT Cir-2, Kota

In the result the appeal of

ITA 199/JPR/2025[2022-23]Status: DisposedITAT Jaipur12 Nov 2025AY 2022-23
For Appellant: Shri Mahendra Gargieya, AdvFor Respondent: Mrs. Anita Rinesh, JCIT
Section 143(1)Section 234ASection 250Section 438Section 43B

expenditure nor did the assessee claim any deduction in respect of the amount and considering that the assessee is following the mercantile system of accounting, the question of disallowing the deduction not claimed would not arise. Learned counsel for 10 ITA Nos.197 to 199/JP/2025 Ahluwalia Erectors & Fabricators ... revenue submits that the assessee has sought to evade tax under the mercantile system of accounting. We are of the view that it is not for the revenue authorities to tell the assessee how to maintain its accounts”. 1.4.2 P.K. Parikh HUF v. ITO [2024] 161 taxmann.com 22 (Ahmedabad - Trib

Ahluwalia Erectors & Fabricators Private Limited, Kota vs. DCIT/ACIT Cir-2, Kota

In the result the appeal of

ITA 198/JPR/2025[2021-22]Status: DisposedITAT Jaipur12 Nov 2025AY 2021-22
For Appellant: Shri Mahendra Gargieya, AdvFor Respondent: Mrs. Anita Rinesh, JCIT
Section 143(1)Section 234ASection 250Section 43B

expenditure nor did the assessee claim any deduction in respect of the amount and considering that the assessee is following the mercantile system of accounting, the question of disallowing the deduction not claimed would not arise. Learned counsel for 11 ITA Nos.197 to 199/JP/2025 Ahluwalia Erectors & Fabricators ... revenue submits that the assessee has sought to evade tax under the mercantile system of accounting. We are of the view that it is not for the revenue authorities to tell the assessee how to maintain its accounts”. 1.4.2 P.K. Parikh HUF v. ITO [2024] 161 taxmann.com 22 (Ahmedabad - Trib