2024 (6) TMI 99

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...., ground no. 1 is dismissed as not pressed. 3. In ground no. 2 assessee has challenged the disallowance of provision made for leave encashment. Briefly, the facts are, assessee is a resident corporate entity and stated to be engaged in the business of manufacturing and trading of pesticides and insecticides etc. In assessment year under dispute, assessee filed its return of income on 26.11.2016 declaring income of Rs. 18,34,81,000/-. In course of assessment proceedings, the assessee, through a revised computation of income, claimed deduction of leave encashment amounting to Rs. 1,81,08,383/-. However, the Assessing Officer rejected assessee's claim stating that such claim having not been made through a revised return of income cannot be ....

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....stical purposes. 5. Besides the aforesaid ground, vide letter dated 18.01.2023, the assessee has raised an additional ground on the issue of taxability of excise duty subsidy. Briefly, the facts are, the assessee had set up a manufacturing unit in the state of Jammu & Kashmir. In terms with New Industrial and other concessions scheme issued by the State of Jammu & Kashmir, the assessee availed excise duty subsidy amounting to Rs. 6,17,88,640/- in the year under consideration. 5.1 In the return of income filed for assessment year under dispute, assessee treated the excise duty subsidy as revenue in nature and offered to tax. However, through an additional ground raised before us, the assessee has claimed that the excise duty subsidy is....