Tribunal held  that the issue had to be decided having regard to the terms of the joint development agreement and the intention of the parties to the agreement. Thus, the intention of the parties could be gauged from the entries made in the books of account. The entries in the books of account clearly showed that the assessee was only a partner in the development of scheduled property of the agreement. In any event, no addition could be made based on a mere difference between form 26AS and the amount shown in the profit and loss account and in the absence of any reconciliation and corroborative evidence. It was not the case of the Department that there was leakage of revenue during the period of joint development, the transaction was tax neutral. Therefore, no addition was warranted and the Assessing Officer was directed to delete the addition.(AY. 2016-17)