RANKA, J. - (1.) Instant appeal is directed against the order dated 17.07.2015 passed by the Income Tax Appellate Tribunal (for short ITAT) in ITA No.893/JP/2012. It relates to assessment year 2009-10.
(2.) The brief facts which can be noticed are that the respondent is a corporation established by the Government of Rajasthan and is engaged in procurement, processing and trading of seeds, tractor and agriculture implements. The assessee claims that the accounts are audited. During the course of assessment proceedings the Assessing Officer desired the assessee to explain:- (i) The expenses claimed to the tune of Rs. 9,82,874/- being prior period expenses, (ii) Contribution to LIC Group Gratuity Scheme amounting to Rs. 1,92,82,605/- and, (iii) Contribution to State Renewal Fund at Rs. 7,58,134/-.
(3.) After raising query and seeking explanation all the three amounts as aforesaid were disallowed by the Assessing Officer on the premise (i) that the prior period expenses pertained to earlier assessment years and is required to be allowed, during the previous year relevant to the year under assessment. (ii) the Group Gratuity Scheme was approved by the Commissioner which was mandatory and the same being approved, the deduction under Section 36(1)(V)was allowable. (iii) State Renewal Fund is an allowable expenditure within the provisions of Section 37(1).;