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of <h1>Tribunal orders reassessment on land transfer profits, emphasizing factual verification of sale consideration and construction completion.</h1> <h3>Deputy Commissioner of Income Tax, Circle-8 (1), Hyderabad Versus M/s. Vessella Constructions,</h3> Deputy Commissioner of Income Tax, Circle-8 (1), Hyderabad Versus M/s. Vessella Constructions, - TMI Issues involved:The only issue involved in this appeal is the addition of profits/gains earned by the assessee on the transfer of land pertaining to villas that were sold.Details of the Judgment:The assessee, a partnership concern in the business of property development, took land on development basis and started construction of villas. The Assessing Officer noted discrepancies in the income declared by the assessee and added the balance amount to the income. The assessee contended that revenue was recognized based on the Percentage Completion Method.The CIT(A) found discrepancies in the Assessing Officer's approach and directed the deletion of the addition. The Revenue appealed, arguing that the entire sale consideration should have been disclosed and challenged the deletion of the addition.The Tribunal observed that factual verification of the sale consideration received was necessary. It noted discrepancies in the dates of cheques mentioned in the sale deeds and directed the Assessing Officer to investigate the actual sale consideration received during the relevant year. The Tribunal also found that the construction work was not completed as claimed by the Assessing Officer and directed a thorough inquiry into the revenue recognition method.In conclusion, the Tribunal quashed the previous orders and restored the issue to the Assessing Officer for further investigation. The Assessing Officer was directed to determine the actual sale consideration received and verify the percentage of completion of the project before making a decision. The appeal of the Revenue was treated as allowed for statistical purposes.*Order pronounced in the open court on the 27th day of July, 2023.*
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