Global Entropolis (Vizag) (P.) Ltd. v. ACIT (2019) 178 ITD 179/ 202 TTJ 384 / 183 DTR 297(Bang.)(Trib.)

S. 145: Method of accounting De-reorganisation was done for default on part of customers; thus, change in method of account was on account of proper reasons, AO was not justified in rejecting the books without finding any fault with such change.

Assessee engaged in business of developing residential townships and providing infrastructure services, following percentage completion method of accounting.  During the year, assessee had de-recognised certain sales, of flats as buyers had defaulted in paying instalments, the AO held  that assessee could not derecognize sales as assessee, in any way, would sell flats to some other person and accordingly, he rejected change in method of accounting made by assessee and amount so de-recognized was added to income of assessee.  Tribunal  held  that the assessee has chosen to follow the revised guidance note issued by ICAI for accounting for real estate transactions. Though the revised Guidance note applies to projects commenced on or after 1-4-2012, the guidance note allows the same to be applied for the projects commenced prior to 1-4-2012 also.  The revised Guidance Note provides for de-recognising income, when there is default on the part of customers. Thus, the change in method of account is on account of proper reasons. Therefore Tribunal held that tax authorities are not justified in rejecting the same, without finding fault with the change.   (AY.  2014 15, 2015-16)