Assessee entered into a sub-contract agreement and filed return claiming contract loss. Assessing Officer observed that during proceedings under section 197 seeking lower deduction of tax at source certificate, assessee had projected revenue of entire project and amount stated to be received for relevant year was at huge variation from amount reflected in financial statements. He, thus, passed draft assessment order proposing adoption of estimated revenue and to disallow estimated loss.  It was noted that assessee was following percentage completion of method (PCM) consistently to recognize revenue in books of account.  Also deviation in estimation and actual revenue stood explained by fact that duration of project got extended to financial year 2020-21 which was much beyond agreed original contract period-Whether as per AS-7 any expected excess of total contract costs over total contract revenue for contract is recognized as an expense immediately irrespective of stage of completion of contract activity and following same assessee had recognised contract losses.  Since in application made under section 197, assessee had merely projected contract revenue, these estimations could not be taken to be turnover of assessee disregarding actual revenue earned by assessee.  Since no defect was pointed in books of account by Assessing Officer,  additions were to be deleted.(AY. 2018-19)