Held that the assessee had disclosed the change of method in revenue recognition during the year, the disclosure of the financial impact of such change of method had not been properly brought on record. This made the Assessing Officer to doubt the change of method adopted by the assessee in order to understate the income. The assessee had to disclose financial information for two years in its balance-sheet as on March 31, 2018 and as at March 31, 2017 with the corresponding impact of such change relating to computation of income declared in the earlier years, March 31, 2018 and March 31, 2017. The Assessing Officer was to verify the impact in the financial statements and verify the declared financial impact in both financial years as well as Income-tax computation. The profit declared by the assessee in the earlier years as per old method of accounting and because of change of method of accounting, there may be understatement or overstatement of declared profit. This under or overstatement of profit in the earlier years had to be acknowledged as an impact on such change of profit and ultimately the correct profit alone has to be charged to tax. The matter was remanded to the Assessing Officer to give proper opportunity of being heard to the assessee. That the levy of interest under section 234A was consequential in nature. If there was increase in the taxable income more than the income declared by the assessee, there would be impact of interest on such additional taxable income. Matter remanded to the Assessing Officer. (AY.2018-19)
SH Tech Park Developers P. Ltd. v. ACIT (2024)113 ITR 19 (SN)(Delhi)(Trib)
S. 145 : Method of accounting-Change of method-Advance tax-Interest-Matter remanded. [S. 234A]
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