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

$~111 & 112 IN THE HIGH COURT OF DELHI AT NEW DELHI+ ITA 627/2018 & CM APPL 21439-21440/2018 + ITA 628/2018 & CM APPL 21441-21443/2018 + ITA 628/2018 & CM APPL 21441-21443/2018 THE PR. COMMISSIONER OF INCOME TAX -3 ..... Appellant Through Mr.Ruchir Bhatia, Advocate. versus ENGINEERING PROJECTS INDIA LTD. ..... Respondent Through Mr.Mayank Nagi, Adavocate. CORAM: HON'BLE MR. JUSTICE S. RAVINDRA BHAT HON'BLE MR. JUSTICE A. K. CHAWLA O R D E R% 22.05.2018 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 fact-dependent, no substantial question of law arises. Similar orders have been made in ITA Nos.554 and 556 of 2018 by this Court on 09.5.2018 in the assesse’s case. Appeals are accordingly dismissed. S. RAVINDRA BHAT, J MAY 22, 2018 ndn A. K. CHAWLA, J