Held that the Assessing Officer had arrived at an estimated income applying the present value factor on future estimated earnings, the receipt of which was uncertain. This methodology was not recognised under the Act and only real income had to be assessed to tax. Consistence method followed by the assessee is directed to be accepted .( AY.2016-17)
Cholamandalam Investment and Finance Co. Ltd. v. Asst. CIT (2023)102 ITR 685 (Chennai)( Trib)
S. 145: Method of accounting — Securitisation transactions — Sale to special purpose vehicle against lump sum consideration equal to book value – Offering excess interest spread to tax on proportionate basis as and when accruing over tenure – Method accepted by Revenue — Rule of consistency —Addition is deleted – Real income to be assessed .