Pre-amendment reassessment limitation bars late notices under the preserved regime, invalidating consequential reassessment for affected earlier asses...
Cash-sales explanations for bank deposits require documentary reconciliation; reassessment notice survived where effective response time was available...
Functional comparability in transfer pricing prevents ad hoc arm's length adjustments where functions, assets, risks and reliable comparables are unes...
Income recognition rules and accounting standards for revenue from construction contracts were at issue. The assessee argued that AS-9 was not applicable as it specifically excludes revenue from construction contracts. Section 43CB, introduced with effect from 01.04.2017, mandates revenue recognition based on ICDS-3 for construction contracts. ICDS-3 allows recognizing revenue using the regular method for contracts commenced before 31.03.2016 and not completed by that date. As the assessee's residential project commenced before 31.03.2016 and was ongoing, neither AS-9 nor Section 43CB applied. Consequently, the CIT(A)'s deletion of the addition was upheld, and the Revenue's appeal was dismissed by the Appellate Tribunal.
Income recognition rules and accounting standards for revenue from construction contracts were at issue. The assessee argued that AS-9 was not applicable as it specifically excludes revenue from construction contracts. Section 43CB, introduced with effect from 01.04.2017, mandates revenue recognition based on ICDS-3 for construction contracts. ICDS-3 allows recognizing revenue using the regular method for contracts commenced before 31.03.2016 and not completed by that date. As the assessee's residential project commenced before 31.03.2016 and was ongoing, neither AS-9 nor Section 43CB applied. Consequently, the CIT(A)'s deletion of the addition was upheld, and the Revenue's appeal was dismissed by the Appellate Tribunal.
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