Retrospective application of beneficial circulars upheld, binding officers and granting post adjudication relief where adjudication occurred after cir...
Admissibility of Investigation Statements requires witness examination before the adjudicating authority; otherwise statements cannot sustain a penalt...
Transaction value and connected person treatment in excise valuation: proprietary concerns not inter connected undertakings, relief on valuation and c...
Appointment of Registrars as adjudicating officers under Companies Act reallocates territorial jurisdiction and sets appeal route to Regional Director...
Composite supply of drilling services and site specific chemicals characterised as composite supply; prior advance rulings set aside, tax rate left op...
The dominant issue was whether revenue from sale of flats had to be recognized in the year under the percentage completion method due to alleged crossing of a 25% threshold, despite the assessee consistently following the project completion method. Since the assessee had offered the same sales to tax in subsequent years upon project completion, forcing recognition in the impugned year would cause impermissible double taxation; further, consistency in accepted accounting treatment could not be disturbed absent any change in facts. Accordingly, the addition for unrecognized revenue was deleted. The issue of disallowance of interest under sections 36(1)(iii) and 40A(2)(a) failed because the interest was not claimed in the profit and loss account but capitalized as work-in-progress, so no deduction was to be disallowed. - ITAT
The dominant issue was whether revenue from sale of flats had to be recognized in the year under the percentage completion method due to alleged crossing of a 25% threshold, despite the assessee consistently following the project completion method. Since the assessee had offered the same sales to tax in subsequent years upon project completion, forcing recognition in the impugned year would cause impermissible double taxation; further, consistency in accepted accounting treatment could not be disturbed absent any change in facts. Accordingly, the addition for unrecognized revenue was deleted. The issue of disallowance of interest under sections 36(1)(iii) and 40A(2)(a) failed because the interest was not claimed in the profit and loss account but capitalized as work-in-progress, so no deduction was to be disallowed. - ITAT
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