Held that receipt from TDR is inextricably linked to the project , therefore cost of building has to be deducted against sale of TDR . TDR receipts cannot be considered in isolation , the assessee has the obligation under SRA agreement to complete SRA project Matter remanded. ( TS-1096 -ITAT -2021 (Mum)( AY. 2010-11, 2011-12) ( Dt. 24 -11 -2021 )
DBS Reality v.ACIT ( 2022) BCAJ- February -P. 40 ( Mum)( Trib)
S.145 :Method of accounting – Construction business – Business income -Percent completion project – Cost of project – Income from TDR- SRA project – TDR is inextricably linked to the project – Cost of building has to be deducted against sale of TDR -Matter remanded [ S. 28(1)]