The Pr. Commissioner Of Income Tax -3 v. Engineering Projects India Ltd.

$~27 * IN THE HIGH COURT OF DELHI AT NEW DELHI + ITA 635/2018 & CM APPL. 21725-21727/2018 THE PR. COMMISSIONER OF INCOME TAX -3 ..... Appellant Through:

Mr. Ruchir Bhatia, Sr. Standing Counsel for Revenue.

versus ENGINEERING PROJECTS INDIA LTD.

..... Respondent Through:

Mr. Mayank Nagi, Adv.

CORAM:

HON'BLE MR. JUSTICE S. RAVINDRA BHAT HON'BLE MR. JUSTICE A. K. CHAWLA

O R D E R

% 23.05.2018 Questioning the common order of the Income Tax Appellate Tribunal (ITAT) under Section 260A of the Income Tax Act, 1961, the Revenue is aggrieved in its appeal. The Assessing Officer (AO) had brought to tax certain amounts for the two AYs in question, holding that they are prior period expenses and, therefore, could not be allowed.

The CIT(A), after detailed analysis of the facts, held that the liabilities had crystallized on account of the assessee's contractual relationship and, therefore, set aside the AO's order. The ITAT affirmed that view. This Court is of the opinion that since the findings are intensely factdependent, no substantial question of law arises. The appeal is accordingly dismissed.

S. RAVINDRA BHAT, J A. K. CHAWLA, J MAY 23, 2018/kks