Held that the assessee-firm, engaged in the business of real estate development, had been consistently following the Project Completion Method (PCM) for recognition of revenue since inception, and the same method had been accepted by the Department in all preceding assessment years. Assessing Officer applied the Percentage Completion Method (PCM) and made an addition. Tribunal held that since the Assessing Officer had not pointed out any change in factual or legal position warranting deviation from consistently accepted accounting method, the application of the Percentage Completion Method by the Assessing Officer was unjustified. Tribunal also held that an addition made merely on the basis of a statement recorded during survey proceedings under sections 133A/131, without any corroborative evidence, could not be sustained. AY. 2019-20)
DCIT v. Amardeep Constructions. (2025) 215 ITD 322 (Mum) (Trib.)
S. 145: Method of accounting-Project completion method (PCM)-Real estate developers-Consistently accepted-Application of Percentage Completion Method by Assessing Officer was unjustified-Survey-Merely on basis of a statement recorded during survey proceedings under sections 133A/131, without any corroborative evidence, could not be sustained. [S.131, 133A]
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