Assessee-company is  engaged in building infrastructure projects Assessee had received project development fees of certain amount. It had apportioned project development fees over entire period of projects and had accordingly offered only a certain amount to tax during relevant year. However, Assessing Officer treated said fees as taxable entirety in relevant year. Tribunal held that  since Project work could not be completed within one year, services to be rendered by assessee would automatically spill over to succeeding years of project period and accordingly, fees would be apportioned to subsequent year of contract period.   Further, since project development fees apportioned to subsequent years had also been returned to tax by assessee in said years, department in any case had not been deprived of any tax.Therefore, entire fee could not be brought to tax during year and same was to be apportioned over period of project.  (AY. 2010-11)