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Shreya Creations P. Ltd. Vs. CIT(A)-50, Mumbai

Case No: ITA No.6958/Mum/2025
Court: INCOME TAX APPELLATE TRIBUNAL “G” BENCH, MUMBAI
Date: 1/23/2026

Parties Involved

appellantShreya Creations P. Ltd.
respondentCIT(A)-50, Mumbai

Facts Summary

The assessee, Shreya Creations P. Ltd., is a resident corporate entity involved in the entertainment industry. For the assessment year 2011-12, the assessee filed its return of income on 28.12.2011, declaring NIL income under normal provisions and a book profit of Rs.1,49,65,787/- under section 115JB of the Income Tax Act, 1961. During the assessment proceedings, the Assessing Officer found a discrepancy between the income declared by the assessee and the TDS and corresponding income reflected in Form-26AS, amounting to Rs.37,13,011/-. The Assessing Officer called upon the assessee to reconcile this difference. Although the assessee provided submissions claiming no such difference, the Assessing Officer added back the amount of Rs.37,13,011/-. The assessee contested this addition before the First Appellate Authority, but it was sustained. Before the Tribunal, the assessee's counsel provided a detailed reconciliation, explaining that the major difference was due to receipts from Zee Entertainment amounting to Rs.33,63,403/-. The assessee follows an accounting system where bills are issued upon finalization and approval of work, and income is booked accordingly. The payees deducted TDS as per their cost provision, leading to a mismatch in the assessment year.

Decision in favour of

Assessee

Legal Issues

  • 1. Addition of an amount of Rs.37,13,011/- on account of difference between income offered by the assessee and as reflected in Form-26AS.

Judgment Outcome

Decided in favour of Assessee.

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Shreya Creations P. Ltd. Vs. CIT(A)-50, Mumbai | ITA No.6958/Mum/2025 | 2026 | Opakhya