Project completion method upheld for real estate accounting where no substantial question of law arose

The project completion method under Accounting Standard 9 was upheld as correctly applicable to the assessee's real estate business because it had been consistently followed in earlier years and already accepted by the Tribunal for prior assessments. The Court relied on earlier rulings recognising the distinction between the project completion method and the percentage completion method, and held that the former could not be rejected merely because it defers tax payment. In the absence of any new factual development or legal basis showing the method to be inappropriate, the Revenue's challenge did not raise a substantial question of law.

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Issues: Whether the project completion method under Accounting Standard 9 was correctly applied to the assessee's real estate and whether any substantial question of law arose from the Tribunal's acceptance of that method.

Analysis: The assessee had consistently followed the project completion method in earlier years, and the Tribunal had already accepted that method as applicable to its business for prior assessment years. The Court noted that earlier decisions had recognised the distinction between the percentage completion method and the project completion method, and had held that the latter could not be rejected on the ground that it necessarily deferred tax payment. In the absence of any new factual development or legal rationale showing that the method was inappropriate for the assessee, the Revenue's challenge to the Tribunal's view did not raise a substantial question of law.

Conclusion: The project completion method was held to be correctly applicable, and the Revenue's appeal failed.

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