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Jcit(Osd)(E) Circle-2(1), New Delhi vs Population Services International, ... on 12 February, 2024 cites

Sun Pharmaceuticals Industries Ltd. ( ... vs The Acit,Cent.Circle-1, Baroda on 8 April, 2021

21. The allegation of the Special Auditor that the assessee has not maintained separate books of account for the purpose of foreign contribution under the Foreign Contribution Regulation Act, 2010, is equally unacceptable. As brought to our notice by learned counsel for the assessee, there is no mandate under the Foreign Contribution Regulation Act, 2010 to maintain separate ITA No. 1805/Del/2023 10 books of account for foreign contribution and business activities. The only requirement in law is, the assessee must maintain separate bank accounts for foreign contribution, which the assessee has complied. It is noteworthy, before the departmental authorities, the assessee has specifically submitted that its accounts are maintained in ERP software, viz., "Lawson" to record transaction. It is understood, ERP software can be used to compute figures of any segment of the entity. Further, we have noted, in case of Ranbaxy Laboratories Ltd. Vs. ACIT (supra), the Coordinate Bench, while considering the issue whether separate books of account are required to be maintained where the accounts are maintained on SAP ERP System, has observed that SAP based ERP system of accounting tantamount to maintenance of separate books of account. Thus, applying the ratio laid down by Coordinate Bench, we have to accept assessee's plea that there is no necessity of maintaining separate AR books of account, once the accounts are maintained in ERP system. Thus, in view of the aforesaid, the allegation of the CIT (Exemption) that due to non-maintenance of separate books of account the condition of 7th proviso to section 10(230) of the Act is violated, deserves to be rejected.
Income Tax Appellate Tribunal - Ahmedabad Cites 121 - Cited by 61 - Full Document
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