Prolonged sterilisation of development rights supports capital-gains treatment, while business-income disallowances cannot govern capital-gains comput...
Additional evidence in transfer pricing dispute leads to fresh examination, while tax deductions, TDS credit, fee and refund interest require verifica...
Category II AIF pass-through taxation preserves non-business income character; investment receipts cannot be reclassified without applying recognised ...
Mutual fund maturity rules require proper rollover, redemption, disclosure, and due diligence; investor gains cannot excuse regulatory breaches or pen...
Threshold exemption excludes exempt services, while stamp-paper purchases avoid reverse charge; consequential service tax penalties were also set asid...
ITAT holds that, applying the ICAI Guidance Note on Real Estate Accounting (Revised 2012), land and development rights qualify as direct project costs but must be excluded when determining the 25% construction-and-development-cost threshold to trigger revenue recognition under the Percentage of Completion Method (POCM); once that threshold is met using construction and development costs, total project costs (including land) determine stage of completion and revenue to be recognized. The taxpayer's POCM application was correct: Phase-1 exceeded the 25% threshold whereas Phase-2A did not (19.5205%), and unreconciled revenue was recognized in subsequent years at unchanged tax rates. Absent evidence of deliberate evasion or inconsistent accounting, ITAT found the AO and lower authority's additions unjustified, directed vacatur of those additions and allowed the taxpayer's appeal.
ITAT holds that, applying the ICAI Guidance Note on Real Estate Accounting (Revised 2012), land and development rights qualify as direct project costs but must be excluded when determining the 25% construction-and-development-cost threshold to trigger revenue recognition under the Percentage of Completion Method (POCM); once that threshold is met using construction and development costs, total project costs (including land) determine stage of completion and revenue to be recognized. The taxpayer's POCM application was correct: Phase-1 exceeded the 25% threshold whereas Phase-2A did not (19.5205%), and unreconciled revenue was recognized in subsequent years at unchanged tax rates. Absent evidence of deliberate evasion or inconsistent accounting, ITAT found the AO and lower authority's additions unjustified, directed vacatur of those additions and allowed the taxpayer's appeal.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4805
Join Channel
TaxTMI 
