9911796707
TMI Blog2021 (7) TMI 438X X X X Extracts X X X X X X X X Extracts X X X X ..... er made a similar addition as made in this year, in appeal, Ld. CIT(A) deleted the same. It is submitted by the Ld. AR that no appeal was preferred by the Revenue against the relief granted by the Ld. CIT(A) for the assessment year 2014-15 and it has become final. Though the AO had taken a similar objection for the assessment year 2014-15, it was returned down by the Ld. CIT(A) in appeal and the Revenue accepted the same. Such an acceptance of Revenue is not only for the assessment year 2014-15 but it continued for the subsequent years 2015-16 and 2016-17 and more particularly for the assessment year 2017-18 in which year though the learned Assessing Officer record the return for scrutiny under section 143(3) of the Act, did not take any ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... n interest obligation on the part of Muthoot; that the assessee is entitled to interest on these NCDs; and that the assessee has opted/chosen to receive interest on the maturity/redemption of these Debentures. As per the Allotment Advice, the assessee is entitled to receive interest on the expiry of 66 months from the date of allotment. Prospectus also makes it clear that the assessee has chosen to receive interest on the date of redemption of NCDs. It is, therefore, evident that on the expiry of 66 months, the assessee is entitled to receive ₹ 2,000/- representing ₹ 1,000/- being the face value of NCD and ₹ 1,000/- being the interest for 66 months. The assessee, however, in order to comply with the Accounting Standard, ha ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ng the contention of the assessee for subsequent years. 5. Per contra, it is argued by the Ld. DR that the assessee has been following the Mercantile system of accounting and therefore, the interest accrued in this year was rightly added by the learned Assessing Officer and the orders of the authorities below are in perfect consonance with the accounting policy of the assessee. 6. We have gone through the record in the light of the submissions made on either side. Apart from the contentions relating to the matter of accountancy followed by the assessee, it remains an admitted fact that for the assessment years 2015-16 and 2016-17 there was no objection from the learned Assessing Officer in respect of non-inclusion of this particular i ..... X X X X Extracts X X X X X X X X Extracts X X X X
|
