ACIT v. Delhi Buildwell (P.) Ltd. (2025) 213 ITD 291 (Delhi) (Trib.)

S. 37(1): Business expenditure-Unrealised debtors-Write-off-Income offered in the subsequent years when realised-Order of CIT(A) deleting the addition was affirmed.

Assessee-company was engaged in business of real estate. Assessee out of total receipts had deducted a sum on account of unrealized debtors by claiming that this amount pertained to maintenance charges which was not received after expiry of three months from the date of the bill and, therefore, recovery of such amount was doubtful. Accordingly, said amount was reduced from gross receipts. This practice was consistently followed by assessee on regular basis and income on such unrealised debtors were offered for tax as and when amount was received in subsequent years and same was accepted by revenue without any doubts in subsequent assessment years  Assessing Officer,however, made addition of said amount.  CIT A) deleted the disallowance.On appeal by revenue, the Tribunal held that following the principle of consistency and further looking to the fact that said amount had already suffered tax in subsequent years when said sum was realised, the order of CIT(A) deleting the additions was affirmed.  (AY. 2019-20)

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