CIT v. Bhageeratha Engineering Ltd. (No. 1) (2022) 448 ITR 81/288 Taxman 737 (Ker.)(HC) CIT v. Bhageeratha Engineering Ltd. (No. 2) (2022) 448 ITR 93/142 Taxmann.com 155 (Ker.)(HC)Editorial: SLP of revenue dismissed , CIT v .Bhageeratha Engineering Ltd. (No. 2)( 2022) 289 Taxman 10(SC)

S. 145 : Method of accounting-Change of method-Mercantile System of accounting to completed contract accounting-Change is bonafide-Income-Accrual-Bills certified as relating to work completed in relevant assessment year cannot be recognised as receipts and brought to tax. [S. 4, 5]

On reference the Court held that once it was held that the completed contract method adopted by the assessee in the facts and circumstances was right, the bills certified as relating to work completed could not be recognised as receipts and brought to tax in the assessment year 1986-87. The question that mercantile system of accounting should be directed would curtail the discretion available to the assessee. Court also held that since the assessee was subjected to vagaries and uncertainties of fluctuation, it had preferred to have completed contract method for the entire project. The effect of these transactions and recognition of revenue would arise either upon completion of the contract or rescission of contract, other foreseen and unseen eventualities that arose in the course of the execution of the contract. In view of the finding of fact recorded by the Tribunal and having regard to the deferred payment agreement entered by the assessee, the bills having been certified did not create an enforceable right even in the subsequent assessment year.(AY.1986-87). (AY. 1987-88 to 1991-92)