Bata India Ltd. v. DCIT (2020) 180 ITD 464 (Kol) (Trib.)

S.37(1): Business expenditure – lease rent – lease rent expenditure was recognized on straight-lining basis, which led to creation of additional lease rental liability in relevant assessment year, would be deductible – Incremental liability on account of lease rental equalization provided for pursuant to adoption of AS-19 having accrued during relevant previous year was allowable deduction in computing income for said year, notwithstanding that such liability may relate to earlier years.[ S.145, AS -19 ]

Assessee-company  in view of AS-19, decided to recognize scheduled rent increase over lease term on a straight-lining basis . On accounting of escalating rentals in operating lease agreements, it led to creation of additional lease rental liability in relevant year which was debited to profit and loss account under head ‘Rent Straight-Lining’ .The AO disallowed the claim .On appeal CIT (A) allowed the claim  .Tribunal held that since profits so determined after accounting for expense towards straight-lining of lease rentals reflected a better & accurate picture of true commercial profits of assessee-company and there are no contrary or specific provisions in Act, in respect of accounting of lease rentals, expenditure so recognized in profit and loss account was deductible while computing profits of business . Incremental liability on account of lease rental equalization provided for pursuant to adoption of AS-19 having accrued during relevant previous year was allowable deduction in computing income for said year, notwithstanding that such liability may relate to earlier years . (AY. 2008 -09)