2015 (5) TMI 182

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....addition of Rs. 1,14,63,360/- made by the AO on account of provision of expenses. In the assessee's cross objection, the solitary ground that is raised is with reference to the validity of reopening the assessment by issuance of notice u/s 148 of the Act. 3. We shall first adjudicate the Revenue's appeal. Revenue's Appeal (ITA No.2643/Del/2012) 4. Brief facts with reference to Revenue's appeal are as follows. The assessee is a company. The assessee filed its return of income on 30.10.2004, disclosing total income of Rs. 2,55,93,730/-. The assessment u/s 143(3) was completed on 31.08.2006, determining the total income at Rs. 2,65,66,342/-. Thereafter, notice u/s 148 was issued on 06.03.2009 and reassessment u/s 147 r.w.s. 143(3) ....

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....ntered with such party. The assessee, in fact, even deducted TDS of Rs. 49,171 at the end of the year against aforesaid expense, which establishes the accrual of aforesaid expense and certainty the amount of liability there against. Similarly, the provision has been made for statutory audit fee for the relevant financial year, which is an expense of the relevant year, for which the amount of liability is ascertained on the basis of fees agreed with the auditor and, therefore, the liability there against was provided for in the books of account. To the same effect is the provision for bonus payable to employees in relation to service rendered during the year which got accrued during the year and the liability there against is ascertained. In....