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ITAT allowed the appeal of the assessee, deleting the addition...

Appeal allowed, cash basis for duty drawback accepted, under-reporting addition deleted applying consistency and s.145 income recognition principles

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Income Tax November 27, 2025 Case Laws AT
ITAT allowed the appeal of the assessee, deleting the addition made on account of alleged under-reporting of duty drawback. ITAT held that the assessee's consistent and bona fide accounting policy of recognizing duty drawback income on receipt (cash) basis, in line with prudence and prevailing trade practice, is acceptable and does not distort true income. It noted that the assessee had substantiated the actual duty drawback received during the relevant year through ledgers and sample shipping bills and that there was no revenue leakage, as the timing difference arose solely from the method of accounting. Applying the principles of consistency and recognizing that the right to receive becomes taxable on receipt basis in such circumstances, ITAT concluded that the method followed was fair and valid. Consequently, the addition made by the lower authorities was set aside and the assessee's appeal was allowed in full.

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Acts Income Tax