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Category II AIF pass-through taxation preserves non-business income character; investment receipts cannot be reclassified without applying recognised ...
Assessee followed system of regularly showing mobilization account and advances received, offering income against bills in subsequent years. Revenue did not previously object to this treatment. CIT(Appeals) and Tribunal deleted additions made by Assessing Officer on account of "Mobilization Advance" for the year. Statements of Samiti members showed lack of full knowledge on work progress, with Sub Divisional Engineer overseeing the matter. Work completion certificates indicated work was completed later and income offered for taxation in subsequent years. Non-commensurate work-in-progress amount of Rs. 69,31,666 did not justify treating advances as income. Assessing Officer added Rs. 2,00,95,900 as unaccounted receipts from Samiti, failing to note it was already shown as liability in books. No instance to interfere with CIT(Appeals) observations. CIT(Appeals) order upholding dismissal of Revenue's grounds was affirmed.
Assessee followed system of regularly showing mobilization account and advances received, offering income against bills in subsequent years. Revenue did not previously object to this treatment. CIT(Appeals) and Tribunal deleted additions made by Assessing Officer on account of "Mobilization Advance" for the year. Statements of Samiti members showed lack of full knowledge on work progress, with Sub Divisional Engineer overseeing the matter. Work completion certificates indicated work was completed later and income offered for taxation in subsequent years. Non-commensurate work-in-progress amount of Rs. 69,31,666 did not justify treating advances as income. Assessing Officer added Rs. 2,00,95,900 as unaccounted receipts from Samiti, failing to note it was already shown as liability in books. No instance to interfere with CIT(Appeals) observations. CIT(Appeals) order upholding dismissal of Revenue's grounds was affirmed.
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