DCIT CIRCLE-1, RANCHI V. URMILA RCP PROJECTS PVT LTD, RANCHI

ITA 146/RAN/2019

AI Insights

The case involves two appeals: one by the revenue and another by the assessee, M/s. Urmila RCP Project Pvt Ltd., against the order of the CIT(A), Ranchi. The appeals pertain to the assessment year 2015-16. The primary issue revolves around the disallowance of certain expenses by the Assessing Officer, who deemed them as inadmissible and contingent liabilities. The CIT(A) had partially deleted and confirmed some of these disallowances, leading to the current appeals. The Tribunal decided to restore the matter to the Assessing Officer to allow the assessee to substantiate the expenses with proper bills and details.

• Counselvise Citation: [2025] 140 COUNSELVISE.COM (IT) 633536 (ITAT-RANCHI)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 09-06-2025
• Appeal Filed By: Department
• Order Result: Partly Allowed
• Bench Allotted: DB
• Assessment Year: 2015-2016
• Result in Favour of: Partly Allowed
• Court: TRIBUNAL
• Department Lawyers: RINKU SINGH
• Assessee Lawyers: SHRIMANJIT VERMA

Judgement Text

"IN THE INCOME TAX APPELLATE TRIBUNAL, BEFORES/ AND RATNESH NANDAN SAHAY, ACCOUNTANT MEMBER Dy.CIT, Circle- PAN/GIR No. (Appellant M/s. Urmila RCP Project Pvt Ltd., 1 RCP Complex, Kadru, Ranchi-834002 PAN/GIR No.AACCR 5201 P (Appellant IN THE INCOME TAX APPELLATE TRIBUNAL, RANCHI BENCH, RANCHI S/SHRI GEORGE MATHAN, JUDICIAL AND RATNESH NANDAN SAHAY, ACCOUNTANT MEMBER ITA No.146/RAN/2019 Assessment Year: 2015-16 -1, Ranchi Vs. M/s. Urmila RCP Project Pvt Ltd., 1 RCP Complex, Kadru, Ranchi-834002 .AACCR 5201 P (Appellant) .. ( Respondent ITA No.54/RAN/2019 Assessment Year: 2015-16 M/s. Urmila RCP Project Pvt Ltd., 1 RCP Complex, Kadru, 834002 Vs. Dy.CIT, Circle .AACCR 5201 P (Appellant) .. ( Respondent Assessee by : Shri Manjit Verma, CA Revenue by :Smt. Rinku Singh, CIT DR Date of Hearing : 09/06/ Date of Pronouncement : 09/06/ O R D E R P a g e 1 | 4 IN THE INCOME TAX APPELLATE TRIBUNAL, , JUDICIAL MEMBER AND RATNESH NANDAN SAHAY, ACCOUNTANT MEMBER M/s. Urmila RCP Project Pvt Ltd., 1 RCP Complex, Kadru, 834002 Respondent) Dy.CIT, Circle-1, Ranchi Respondent) Manjit Verma, CA CIT DR /2025 /2025 ITA No.146/RAN/2019 ITA No.54/Ran/2019 Assessment Year: 2015-16 P a g e 2 | 4 Per Bench ITA No.146/Ran/2019 is an appeal filed by the revenue and ITA No.54/Ran/019 is an appeal filed by the assessee against the order of the ld CIT(A), Ranchi dated 31.1.2019 in Appeal No.CIT(A),Ranchi/10260/2017-18 for the assessment year 2015-16. 2. Smt. Rinku Singh, Ld CIT DR appeared for the revenue and Shri Manjjt Verma, ld AR appeared for the assessee. 3. It was submitted by ld CIT DR that in the course of assessment, the Assessing Officer had disallowed certain expenses as inadmissible expenses by holding the same as contingent liabilities. The break-up of the expenses is found at pages 5-6 of the assessment order in para 3. The reasons for the disallowance have been brought out by the Assessing Officer in para 3.1 and 3.2 of the assessment order. It was the submission that none of the bills to prove the expenses had been produced before the Assessing Officer. It was the further submission that before the ld CIT(A), the assessee had provided a chart which was shown at page 19 of the order of the ld CIT(A), wherein, various details and some chart had been produced. It was the submission that the on the basis of the chart and submission of the assessee, the ld CIT(A) has in para 5.4 of his order at page 26, deleted the addition to an extent of Rs.4,16,26,731/- and has confirmed the disallowance to an extent of Rs.56,18,171/-. In regard to part of the expenses disallowed to an extent of Rs.4,16,26,731/-, the revenue is in ITA No.146/RAN/2019 ITA No.54/Ran/2019 Assessment Year: 2015-16 P a g e 3 | 4 appeal in ITA No.146/Ran/2019 and in regard to the confirmation of disallowance of the expenses to an extent of Rs.56,18,971/-, the assessee is in appeal. 4. It was the submission that no details having been produced before the Assessing Officer, the deletion of the disallowance by the ld CIT(A) was not permissible. It was the further submission that the revenue has no objection, if the issues in this appeal are restored to the file of the Assessing Officer for examination of the expenses subject to the assesseeproviding the details of expenses of the expenses having been incurred. 5. When the ld AR was asked to produce the details of the bills of expenses having been incurred, ld AR replied that he is not in a position to immediately provide the same. It was the submission that he is willing to produce the same before the Assessing Officer. 6. We have considered the rival submissions. As it is noticed from the assessment order that the assessee has not provided any of the bills in respect of the said expenses before the Assessing Officer and has produced the evidence before the ld CIT(A), in the interest of justice, the issues in both the appeals are restored to the file of the Assessing Officer so that the assessee can produce the bills of the expenses and the Assessing Officer shall examine the same. Should the assessee not able to produce such bills/details of expenses, the expenses shall not be allowed . The Assessing Officer also shall keep in mind that the assessee is following mercantile system of accounting. ITA No.146/RAN/2019 ITA No.54/Ran/2019 Assessment Year: 2015-16 P a g e 4 | 4 7. In the result, appeal of the revenue and appeal of the assessee stand partly allowed for statistical purposes. Order dictated and pronounced in the open court on 9/06/2025. Sd/- Sd/- (RATNESH NANDAN SAHAY) (GEORGE MATHAN) ACCOUNTANT MEMBER JUDICIAL MEMBER Ranchi; Dated 09/06/2025 B.K.Parida, SPS (OS) Copy of the Order forwarded to : By order Sr.Pvt.secretary ITAT, Ranchi 1. The Appellant /Revenue; Dy.CIT, Circle-1, Ranchi 2. The Respondent/Assessee; M/s. Urmila RCP Project Pvt Ltd., 1 RCP Complex, Kadru, Ranchi-834002 3. The CIT(A)-Ranchi 4. Pr.CIT,Ranchi 5. DR, ITAT, 6. Guard file. //True Copy// "