No Tax on Inter-Circle Reconciliation Differences: ITAT Deletes ₹1,527 Crore Addition

ACIT Vs Bharat Sanchar Nigam Pvt. Ltd. (ITAT Delhi) Conclusion: Inter/Intra Circle Remittance Balance represented only internal transfer and reconciliation entries relating to assets and stock in transit between different Circles of the Assessee company. Since no expenditure or deduction had been claimed and the balances did not represent any real income or loss, the addition of Rs.1527.40 crores made by the AO and confirmed by the CIT(A) was deleted. Held: Assessee company operated through approximately 47 Circles and 700 Accounting Units spread across various States in India. Its operations...