2016 (5) TMI 397

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....11, claiming following substantial question of law:- " Whether on the facts and in the circumstances of the case, the learned ITAT has erred by upholding the order of CIT(A) and deleting the additions made on account of provision for arrears of salary of Rs.  2,04,52,413/- being as prior period expenses and contingent liabilities?" 2. A few facts relevant for the decision of the controversy involved as narrated in the appeal may be noticed. The respondent-assessee is a government undertaking engaged in the activities of manufacturing and sale of feed, pesticides, storage of agriculture produce and trading of agricultural implements and agriculture related activities. It filed its return of income on 13.10.2010 by declaring ....

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....was not accepted by the Assessing Officer as the provision made was allowed only in the year of payment irrespective of the accounting method followed by the assessee and further no liability had incurred in the said case. Accordingly, assessment order dated 4.2.2013, Annexure A.1 was passed by the Assessing Officer. Aggrieved by the order, the assessee filed appeal before the Commissioner of Income Tax (Appeals) [CIT(A)]. Vide order dated 27.12.2013, Annexure A.2, the CIT(A) partly allowed the appeal deleting the addition made by the Assessing Officer on account of provision of arrears of salary amounting to Rs.  2,04,52,413/-. Not satisfied with the order, the revenue filed appeal before the Tribunal. Vide order dated 10.9.2015,Annex....