J N Tekrawala Construction Ltd. v. ITO (2025) 307 Taxman 236 (Guj.)(HC)

S. 145: Method of accounting-Project competition method-Civil construction-Order of the Tribunal estimating the income at 8% on the basis of receipt was deleted-Directed the Assessing Officer to accept the project competition method. [S. 260A]

 Assessee was engaged in the business of civil construction on a contractual basis. In respect of contract receipts from one, Gujarat Torrent Energy Corporation Ltd (GTEC)  assessee followed the project completion method. Assessing Officer noticed that assessee received payment from GTEC on the basis of RA bills raised from time to time and estimated profit at 8 per cent on the basis of receipts from GTEC and made an addition to assessee’s income. Tribunal confirmed the addition made by the Assessing Officer. On appeal, the Court held that the assessee had followed the project completion method since 1992 in respect of the project with GTEC.   Since the assessee had followed a method of accounting which was well recognised and was in consonance with standard accounting practice, more particularly as per revenue recognition note forming part of account, which disclosed that assessee had followed project completion method as per Accounting Standard-7 in respect of said contract, addition made on account of income estimated at 8 percent was deleted. (AY. 1998-99)

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