Assessee recognised application fees, front-end fees, administrative fees and processing fees on realization basis, whereas Assessing Officer taxed the same on an accrual basis. Issue was covered in favour of assessee by earlier decisions of the Tribunal and the jurisdictional High Court, Housing & Urban Development Corporation Ltd. v ACIT (2020) 421 ITR 599(Bom)(HC). Therefore, additions made by recognising such fees on an accrual basis were deleted. (AY. 2012-13, 2014-15, 2015-16)
Housing & Urban Development Corporation Ltd. v. DCIT [2025] 128 ITR 387 (Delhi)(Trib.)
S.28(i): Business income-Application fees, front-end fees and processing fees -Recognition on realization basis –Addition on an accrual basis was deleted.[S. 4, 5, 145]
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