2020 (12) TMI 1029

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....011 by ITO-2(1), Indore. 2. The assessee has raised following grounds of appeal: 1.On the facts and circumstances of the case and in law the learned Commissioner of Income Tax (Appeal)-I ("CIT(A),,) erred in confirming the disallowance of license fees paid in earlier year but crystallized during year. 2.On the fact and circumstances of the case and in law the learned AO ought to have allowed the claim following the principle of consistency in not assessing such advance payment for license fees. 3.Without prejudice to above the learned CIT(A) erred in not giving full effect to the cash system of accounting as considered by the AO. 4. The Appellant humbly prays that the said disallowance be deleted. ....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....Ld. A.O. Now the assessee is again in appeal before the Tribunal. 4. Ld. Counsel for the assessee referring to the paper book and the written submissions submitted that as per the Government regulations the assessee is required to pay the licence fees in advance i.e. before the commencement of the year for which the licence is applied. In case the licence is not granted it is refunded and in case it is granted then it is claimed as an expenditure for the year to which it pertains. It was submitted that the assessee is following the cash system of accounting but since the alleged amount was an advance paid for next year and was also shown as an advance in the balance sheet and only when the licence was granted the expenditure got crystall....