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...
Whether income from a landowner's revenue share under a JDA accrued by applying the percentage completion method was examined. It was held that revenue cannot be recognized until significant risks and rewards pass, which in case of immovable property occurs only upon execution and registration of the sale deed; mere agreements to sell or advance bookings do not effect transfer or accrual, and advances remain liabilities until possession and registered conveyance. As the landowner had only licensed development through a power of attorney, and consistently followed the project completion method, the tax authority could not mandate the percentage completion method merely because the developer used it. Accordingly, the addition for accrued income was rejected. - ITAT
Whether income from a landowner's revenue share under a JDA accrued by applying the percentage completion method was examined. It was held that revenue cannot be recognized until significant risks and rewards pass, which in case of immovable property occurs only upon execution and registration of the sale deed; mere agreements to sell or advance bookings do not effect transfer or accrual, and advances remain liabilities until possession and registered conveyance. As the landowner had only licensed development through a power of attorney, and consistently followed the project completion method, the tax authority could not mandate the percentage completion method merely because the developer used it. Accordingly, the addition for accrued income was rejected. - ITAT
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
