ITO v. Harmony Vinimay (P.) Ltd. (2025) 123 ITR 458 / 174 taxmann.com 1239 (Kol.)(Trib.)

S. 145: Method of accounting-Business expenditure-Real estate developer-Project completion method-Percentage completion method-Consistent method of accounting accepted in earlier year-No justification to change method-Addition deleted.[S. 28(i),37(1), Accounting Standard-9.]

The assessee, a real estate developer, consistently followed the project completion method and recognised revenue in accordance with Accounting Standard-9. The Assessing Officer rejected the method and computed income under the percentage completion method by applying Accounting Standard-7 and ICDS-III. The Tribunal held that the assessee’s method had been accepted by the Revenue in the preceding assessment year and there was no change in facts warranting a departure. The Assessing Officer had also wrongly adopted the wholesale value of the entire project, including the co-owners’ share, though revenue was to be divided among all co-owners. As the project ultimately resulted in a loss, the addition made on the percentage completion method was rightly deleted. (AY. 2018-19).

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