2026 (1) TMI 29

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.... MEMBER AND SHRI NARENDRA PRASAD SINHA, ACCOUNTANT MEMBER For the Assessee : Shri Samir Parikh, AR For the Revenue : Shri Sudhakar Verma, DR ORDER PER NARENDRA PRASAD SINHA, ACCOUNTANT MEMBER: The captioned appeal of the Revenue and the Cross Objection of the assessee is directed against the order of the Additional/Joint Commissioner of income Tax (A)-1, Ludhiana dated 20.03.2025 fo....

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.... pertaining to DAE fund and guarantee, which were contingent liabilities. 4. Shri Sudhakar Verma, the Ld. Sr. DR appearing for the Revenue, explained that while processing the return of the assessee for the A.Y. 2021-22, an adjustment of Rs. 2,69,96,801/- was made by the CPC in respect of contingent liability. He explained that the auditor had reported contingent liability of Rs. 2,69,96,801/- ....

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.... ii) Guarantee issued Rs. 1,58,81,335/- 6.1 The CPC, while processing the return, added this contingent liability of Rs. 2,69,96,801/- on the presumption that the same was debited to Profit & Loss Account. On our specific query, the Ld. Sr. DR could not clarify whether any opportunity was allowed to the assessee before making the disallowance while processing the return. It is found th....