Held that the assessee following project completion method, income quantified on amount of on-money received by assessee on sale of flats ought to be taxed only in year in which project had completed construction in accordance to conditions prescribed as per Revised Guidance Note of 2012 issued by ICAI and thus, income estimated at rate of 25% on-money and taxed in year of receipt was unjustified and deleted. Income estimated at 12 % of on money  as against commissioner estimated at 25% of on money. On money cannot be assessed as cash credits it has to be assessed as business receipts. (AY. 2013-14, 2014-15)