2021 (3) TMI 924

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...., 1961 (the Act) concerning AY 2015-16. 2. The grounds of appeal raised by Revenue read hereunder: "1.1 That in the facts and circumstances of the case, and in law, the Ld. C.I.T.(Appeals) erred in deleting the addition of Rs. 7,92,41,327/- made on account of disallowance of deduction of debit note without appreciating the facts discussed in the assessment order. 1.2 That in the facts and circumstances of the case, and in law, the Ld. C.I.T.(Appeals) erred in deleting the addition of Rs. 7,92,41,327/- made on account of disallowance of deduction of debit note without appreciating that the debit note was stated to have been issued on 18.11.2015, after the end of the financial year, and after the return was filed, and the assessee had no....

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....e (a) of the agreement with GAIL. 4. The AO, however, did not find merit in the claim of the assessee. The AO observed that the accounts have been audited and return of income was filed. The debit note issued on 18.11.2015 falls in F.Y. 2015-16 relevant to AY 2016-17. The AO observed that the liability on account of debit note was not crystallized during the year under consideration and also no provision for this liability was made in the books. He accordingly disallowed the claim so made and added to same to the total income. 5. Aggrieved, the assessee preferred appeal before the CIT(A). The CIT(A) on consideration of facts and circumstances recorded his finding in favour of the assessee which is extracted hereunder: "4.3. I have consi....