Skip to main content

Adani Tracks Management Vs. AO-CPC (Bangalore) Service Limited

Case No: ITA No. 1128/Del/2023
Court: Income Tax Appellate Tribunal, Delhi Benches ‘A’
Date: 1/21/2026

Parties Involved

appellantAdani Tracks Management
respondentAO-CPC (Bangalore) Service Limited

Facts Summary

The assessee, Adani Tracks Management, filed its return of income for the assessment year 2020-21 declaring nil income. After adjusting brought forward business losses and unabsorbed depreciation, the return was assessed by the Central Processing Centre, Bangalore (CPC) and disallowed a payment of gratuity under section 43B of the Income Tax Act for Rs. 9,27,889/-. The assessee had created provisions for gratuity and claimed Rs. 6,51,894/- towards gratuity expense for an employee, Mr. Ajay Bhatnagar, who was transferred to another concern. The Assessing Officer disallowed this claim, stating that it did not fall under section 40A(7) of the Act as there was no actual payment made. The assessee appealed this decision before the Learned Commissioner of Income Tax (Appeals)/National Faceless Appeal Centre (NFAC), Delhi, who partially allowed the claim by permitting the actual payment made to another employee, Mr. Neelesh Singh, but rejected the claim for Mr. Bhatnagar. The assessee then appealed to the Income Tax Appellate Tribunal.

Decision in favour of

Assessee

Legal Issues

  • 1. Whether the claim of Rs. 6,51,894/- towards gratuity expense is allowable under section 40A(7) and 43B of the Income Tax Act, 1961.

Judgment Outcome

Decided in favour of Assessee.

Opakhya LogoOpakhya

AI-powered tax-litigation platform. Find precedents using natural language, draft submissions in minutes, and run your entire case repository from a single secure workspace.

© 2025 Opakhya. All rights reserved.

Core Features

Additional Features

  • Smart Comments
  • Export Options
  • Quick Copy
  • Analytics Dashboard
Version 2.0.1Last updated: October 2025
Powered by AI & Machine Learning