The Assessing Officer rejected the Percentage Completion Method consistently followed by the assessee and taxed the entire sale value of flats sold during the year. The Tribunal held that the Percentage Completion Method is a recognised method of accounting and had been consistently accepted by the Revenue in earlier years. In the absence of any defect in the books of account or change in facts, the Assessing Officer was not justified in discarding the method. The Tribunal found that the profits from the project had already been recognised in earlier years under the Percentage Completion Method and formed part of the closing work-in-progress. Taxing the entire sales again in the year under consideration would result in double taxation. Accordingly, the deletion of the addition by the Commissioner (Appeals) was upheld (AY. 2015-16).
ITO v. Sainath Land Developers (2025) 122 ITR 154 / 170 taxmann.com 431 (Ahd.)(Trib.)
S. 145: Method of accounting-Percentage Completion Method-Consistently followed and accepted-Revenue cannot substitute completed sales method without pointing out defects-Percentage Completion Method-Double taxation avoided-Addition deleted.
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