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The Appellate Tribunal addressed several issues. Firstly, regarding the impact of pay revision of executives, it was held that the provision made by the assessee company for pay revision was justified, as the Delhi High Court's subsequent ruling supported the assessee's position. The provision of Rs. 17.65 crore was deemed necessary for the pay revision. Secondly, the non-grant of TDS credit due to income mismatch was dismissed as the issue had already been resolved by the assessing officer and CIT(A). Lastly, the amortization of deferred grant issue was sent back to the AO for re-verification and re-adjudication, as the AO had rejected the explanations without specific findings. Fairness and natural justice dictate that the issue be reconsidered with the opportunity for the assessee to be heard.
The Appellate Tribunal addressed several issues. Firstly, regarding the impact of pay revision of executives, it was held that the provision made by the assessee company for pay revision was justified, as the Delhi High Court's subsequent ruling supported the assessee's position. The provision of Rs. 17.65 crore was deemed necessary for the pay revision. Secondly, the non-grant of TDS credit due to income mismatch was dismissed as the issue had already been resolved by the assessing officer and CIT(A). Lastly, the amortization of deferred grant issue was sent back to the AO for re-verification and re-adjudication, as the AO had rejected the explanations without specific findings. Fairness and natural justice dictate that the issue be reconsidered with the opportunity for the assessee to be heard.
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