Assessee Can Deduct Mistakenly Reported CENVAT Credit as Income in Later Year, Per Real Income Theory.

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....Prior Period Expenditure - The amount representing CENVAT credit on PSF / UDF and advertisement expenses were wrongly offered as income in assessment years 2010-11 and 2011-12. When an item of income is not received by the assessee and was wrongly offered in the preceding assessment years, the assessee is entitled to claim deduction of such amount in the subsequent assessment year by way of reversal of entries. This is simply on the basis of real income theory and on the principle that if there is no income, there cannot be any tax. - AT....