Co-terminus appellate powers require full verification before deleting TDS disallowances for alleged non-deduction of tax on freight-forwarding paymen...
Section 43CB applies to construction or service contracts, not to self-developed real estate projects undertaken and sold at the developer's own commercial risk. A consistently followed Project Completion Method may continue where the project predates the ICDS-III transitional cut-off and has been accepted in other assessments; the addition under section 43CB was therefore unsustainable. Under the Percentage Completion Method, recognised revenue must match related costs and reflect work performed during the year; using cumulative costs and advances against only current-year expenditure distorted income. Enhancement by treating capitalised work-in-progress as income also requires prior reasonable opportunity to show cause, and capitalised finance, administrative and sales costs do not alone establish accrued revenue.
Section 43CB applies to construction or service contracts, not to self-developed real estate projects undertaken and sold at the developer's own commercial risk. A consistently followed Project Completion Method may continue where the project predates the ICDS-III transitional cut-off and has been accepted in other assessments; the addition under section 43CB was therefore unsustainable. Under the Percentage Completion Method, recognised revenue must match related costs and reflect work performed during the year; using cumulative costs and advances against only current-year expenditure distorted income. Enhancement by treating capitalised work-in-progress as income also requires prior reasonable opportunity to show cause, and capitalised finance, administrative and sales costs do not alone establish accrued revenue.
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