आदेश / O R D E R

PER AMIT SHUKLA (J.M):

The aforesaid appeal has been filed by the Revenue against the impugned order dated 22.07.2025 passed by the learned Commissioner of Income Tax (Appeals), National Faceless Appeal Centre, Delhi, arising out of the assessment order passed under section 143(3) read with section 92CA(4) of the Income Tax Act, 1961 for Assessment Year 2013-14.

2. The Revenue is principally aggrieved by the action of the learned CIT(A) in deleting the disallowance of prior period expenditure amounting to Rs.96,23,13,622/-. According to the Revenue, the assessee had failed to establish that the liabilities corresponding to such expenditure had crystallised during the year under consideration and therefore the expenditure relating to earlier periods could not be allowed as deduction in the present assessment year. The Revenue has further contended that the learned CIT(A) erred in granting relief by following the order of the Tribunal rendered in assessee’s own case for Assessment Year 2012-13 without independently appreciating the facts and evidences pertaining to the year under consideration.

3. Briefly stated, the facts borne out from the record are that the asses