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Income Tax Officer – 26(2)(1) v/s. Svadeshi Enterprises

Case No: ITA No.5865/MUM/2024
Court: INCOME-TAX APPELLATE TRIBUNAL “G” BENCH, MUMBAI
Date: 1/6/2026

Parties Involved

RespondentIncome Tax Officer – 26(2)(1)
AppellantSvadeshi Enterprises

Facts Summary

The assessee, Svadeshi Enterprises, filed its return of income declaring income of Rs.2,56,43,720/-. The case was selected for scrutiny, and the Assessing Officer disallowed an expense of Rs.3cr pertaining to payment to occupants/tenants, considering it a contingent liability. On appeal, the Commissioner of Income-tax (Appeals) allowed the deduction. The assessee raised a cross-objection regarding the jurisdiction of the Assessing Officer, claiming that the Income Tax Officer did not have the au

Decision in favour of

Partly Assessee / Partly Revenue

Legal Issues

  • 1. Whether the Ld.CIT(A) was correct in allowing deduction on account of liability for payment for vacating occupants/tenants.
  • 2. Whether the Ld.CIT(A) was correct in allowing deduction without appreciating that the provision of Rs. 3 Crore during the year does not partake the character of an ascertained/accrued liability.

2 more legal issues analysed in this judgement.

Precedents Relied Upon

6 precedents cited in this judgement.

Judgment Outcome

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