ACIT v. Uttaranchal Jal Vidyut Nigam Ltd. (2022) 94 ITR 435 (Delhi)(Trib.)

S. 145 : Method of accounting-Disputed amount-The tax paid in subsequent year-Double taxation-Same income cannot be taxed twice. [S. 4,5]

The settlement on the disputed sum was arrived at and accepted by both parties during the stage of proceedings before the CIT(A) and which was promptly intimated to the CIT(A). It was observed by the CIT(A) that the PCIT and the Assessee, during the re-assessment pertaining to AY 07-08, 08-09, 09-10 and regular assessment for AY 13-14, agreed that no additions would be done in those years, in consideration of the appellant having owned up and paid tax on the entire amount in AY 2016-17. Therefore, the entire addition made on this account was deleted. (AY. 2012-13)