2024 (9) TMI 635

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....e Order of the Ld. Commissioner of Income Tax (A) is bad in law and on facts. 2. That on the facts and circumstances of the case and in law, the Ld. CIT (A) has erred on considering foreign contribution received during the FY 2020-21 as income of the Assessee based on cash basis method of accounting instead of considering the Income reported in Sr.no. B(i) & B(ii) of Schedule VC based on Accrual basis method thereby, Increasing the income by INR 69,84,169/-, Further that on the facts and circumstances of the case and in law, the Ld. CIT (A) has erred by allowing the addition made in Intimation Order u/s 143(1) and Rectification Order u/s 154 based on difference of accounting principle without considering the fact that under Intimat....

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.... Act on 23.08.2022 determining total income at Rs. 69,84,169/- on account of difference in actual FCRA received by the appellant and income declared by the appellant in its return of income. AO noticed that appellant received FCRA of Rs. 2,77,91,339/- whereas appellant has shown receipts of only Rs. 2,08,07,170/-. Aggrieved by the order appellant filed rectification application. Order u/s 154 of the I.T. Act was passed on 12.01.2023 determining total income of the appellant at Rs. 69,84,169/-. Aggrieved by the order appellant filed appeal. 7.1. Appellant is contending that he has been following Accrual basis method of accounting. Appellant contends that as per the accounting principles the grants received by a Nonprofit organizatio....

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....zed and shown as revenue receipts in the next year. From the return of income of next year filed by the appellant also prove that this unspent receipt was not included in the next year revenue receipts. Hence, the AO has rightly added the amount of Rs. 69,84,169/- to the total income dismissed." 5. As against the order of the Ld. CIT(A), the assessee is before this Tribunal on the Grounds mentioned above. 6. The Ld. Counsel for the assessee submitted that the Ld. CIT(A) erred in considering foreign contribution received during Financial Year 2020-21 as income of the assessee based on cash basis method of accounting instead of considering the income reported in Serial No. B(i) and B(ii) of the Schedule VC based on Accrual basis method ....