Dismissing the appeal of the revenue the Court held that  the Tribunal was justified in confirming the order of the Commissioner (Appeals) deleting the addition made by the Assessing Officer on account of the undisclosed income of Rs. 26,05,00,000 disclosed during the course of survey under section 133A , on the ground that since the assessee followed the project completion method for offering the income to tax, the amount would be subjected to tax upon completion of sale, though the amount had been received earlier from the buyer and in view of the finding of the Commissioner (Appeals) that the assessee in fact, had offered such income to tax in the later years as and when the sale deeds were executed. In his statement the partner of the assessee had agreed that the sum was the undisclosed income of the assessee for the assessment year in question, and had added a clarification that it would be subject to execution of the sale deeds.