The Tax Publishers2019 TaxPub(DT) 2228 (Ahd-Trib)

INCOME TAX ACT, 1961

Section 143(3)

Once income pertaining to prior period was being recognized in the year under consideration and offered for taxation, then equal treatment had to be given to prior period expenditure which were of revenue in nature and crystallized in accounting period relevant to concerned assessment year.

Assessment - Disallowance - Set-off of prior period expenses against prior period income -

Assessee claimed a sum of Rs. 1.81 crores to be netted off against prior period income of Rs. 2.52 crores. AO denied this and disallowed Rs. 1.81 crores. Held: Once income pertaining to prior period was being recognized in the year under consideration and offered for taxation then equal treatment had to be given to prior period expenditure which were of revenue in nature and crystallized in accounting period relevant to concerned assessment year.

REFERRED :

FAVOUR : In assessee's favour.

A.Y. : 2008-09


INCOME TAX ACT, 1961

Sections 14A & 115JB

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