{"id":62183,"date":"2026-07-18T15:29:33","date_gmt":"2026-07-18T09:59:33","guid":{"rendered":"https:\/\/itatonline.org\/digest\/dlf-assets-ltd-v-pcit-2025-132-itr-448-delhi-trib-dlf-ltd-v-pcit-2025-132-itr-448-delhi-trib\/"},"modified":"2026-07-18T15:29:33","modified_gmt":"2026-07-18T09:59:33","slug":"dlf-assets-ltd-v-pcit-2025-132-itr-448-delhi-trib-dlf-ltd-v-pcit-2025-132-itr-448-delhi-trib","status":"publish","type":"post","link":"https:\/\/itatonline.org\/digest\/dlf-assets-ltd-v-pcit-2025-132-itr-448-delhi-trib-dlf-ltd-v-pcit-2025-132-itr-448-delhi-trib\/","title":{"rendered":"DLF Assets Ltd v. PCIT (2025) 132 ITR 448 (Delhi) (Trib.) DLF Ltd. v. PCIT (2025) 132 ITR 448 (Delhi) (Trib.)"},"content":{"rendered":"

Assessee, a real estate developer, changed its method of revenue recognition from percentage-of-completion to completed-contract method per AS-7, making a one-time claim of deduction for reversal of excess revenue booked in earlier years, which was accepted by NFAC as revenue-neutral and consistently followed in subsequent years, but PCIT invoked revision under section 263 directing reconsideration on the former accounting method as well as several other issues including financial expenses, depreciation, current liabilities, deduction under section 80-IAB, house property income, increase in assets, loans and advances to related parties, corporate guarantee expenditure and applicability of section 2(22)(e). On appeal, the Tribunal held that since the change in accounting method was revenue-neutral, being merely a timing difference with no loss to the exchequer, PCIT could not assume revisional jurisdiction under Explanation (c) to section 263(1); and that on each of the other issues, the assessee had furnished detailed replies to specific queries raised by AO during assessment, no defect was pointed out by PCIT in such replies, and his directions, being vague and issued without indicating how AO\u2019s order was erroneous, amounted to impermissible fishing and roving enquiries and an attempt to substitute his own view, particularly where issues such as deduction under section 80-IAB stood already decided in the assessee\u2019s favour by the Tribunal; accordingly, the assessment order was not erroneous or prejudicial to the interests of the Revenue, and the revision order was quashed in its entirety. (AY. 2018-19 & 2019-20)<\/span><\/p>\n","protected":false},"excerpt":{"rendered":"

S. 263: Commissioner-Revision of orders prejudicial to revenue–Real estate business-Change in method of accounting from percentage-of-completion to completed-contract method-Change revenue-neutral, following Accounting Standards, verified by auditors and accepted in subsequent years-No loss to exchequer-Principal Commissioner’s directions to reconsider financial expenses, depreciation, current liabilities, deduction under section 80-IAB, house property income, loans and advances to related parties, etc.-Matters already examined by Assessing Officer-No indication of how order erroneous-Revision amounting to fishing and roving enquiries-Assessment order not prejudicial to Revenue-Revision quashed. [S. 2(22)(e), 80-IAB, 145]<\/p>\n","protected":false},"author":3,"featured_media":0,"comment_status":"open","ping_status":"open","sticky":false,"template":"","format":"standard","meta":{"_acf_changed":false,"_jetpack_newsletter_access":"","_jetpack_dont_email_post_to_subs":false,"_jetpack_newsletter_tier_id":0,"_jetpack_memberships_contains_paywalled_content":false,"_jetpack_feature_clip_id":0,"_jetpack_memberships_contains_paid_content":false,"footnotes":"","jetpack_post_was_ever_published":false},"categories":[21],"tags":[],"class_list":["post-62183","post","type-post","status-publish","format-standard","hentry","category-income-tax-act"],"acf":[],"jetpack_featured_media_url":"","jetpack_shortlink":"https:\/\/wp.me\/p9S2Rw-gaX","jetpack-related-posts":[],"jetpack_sharing_enabled":true,"_links":{"self":[{"href":"https:\/\/itatonline.org\/digest\/wp-json\/wp\/v2\/posts\/62183","targetHints":{"allow":["GET"]}}],"collection":[{"href":"https:\/\/itatonline.org\/digest\/wp-json\/wp\/v2\/posts"}],"about":[{"href":"https:\/\/itatonline.org\/digest\/wp-json\/wp\/v2\/types\/post"}],"author":[{"embeddable":true,"href":"https:\/\/itatonline.org\/digest\/wp-json\/wp\/v2\/users\/3"}],"replies":[{"embeddable":true,"href":"https:\/\/itatonline.org\/digest\/wp-json\/wp\/v2\/comments?post=62183"}],"version-history":[{"count":1,"href":"https:\/\/itatonline.org\/digest\/wp-json\/wp\/v2\/posts\/62183\/revisions"}],"predecessor-version":[{"id":62184,"href":"https:\/\/itatonline.org\/digest\/wp-json\/wp\/v2\/posts\/62183\/revisions\/62184"}],"wp:attachment":[{"href":"https:\/\/itatonline.org\/digest\/wp-json\/wp\/v2\/media?parent=62183"}],"wp:term":[{"taxonomy":"category","embeddable":true,"href":"https:\/\/itatonline.org\/digest\/wp-json\/wp\/v2\/categories?post=62183"},{"taxonomy":"post_tag","embeddable":true,"href":"https:\/\/itatonline.org\/digest\/wp-json\/wp\/v2\/tags?post=62183"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}