Held that the Assessing Officer could not have brought whole profit of project to tax in first year of execution of MoU. Since claim of assessee was not verified by Commissioner (Appeals) and it needed proper verification, matter was to be remitted to file of Assessing Officer to redo assessment de novo and he was to be directed to verify status of project as it could be taxed only to extent of income which accrued to assessee during present assessment year. (AY. 2013-14)
Pearl Coschem (P.) Ltd. v. DCIT (2021) 190 ITD 569 (Mum.) (Trib.)
S. 5 : Scope of total income-Accrual of income-Sale proceeds-Memorandum of understanding (MoU) with SIPL to invest in project to be executed by SIPL-Agreement for sale-Project was not completed-whole profit cannot be taxed in the first year of execution of MOU-Matter remanded. [S. 145]