Co-operative society's mandatory reserve and share capital fixed deposits with banks-interest treated as business income under 80P(2)(a)(iii) deductio...
Income tax reassessment reopening after four years on investigation tip, without s.147 proviso disclosure failure, struck down as borrowed satisfactio...
Dispute concerns revenue recognition where the assessing officer treated finished goods/advances as sales despite the assessee following the project completion method. The tribunal found that the amounts were offered to tax in subsequent assessment years and taxed on profits thereon, making the AO's estimate result in double taxation; accordingly the addition treating such stock/advances as turnover was deleted. Reliance on precedents supporting deletion where income is taxed in later years was noted. Resultantly, all grounds of appeal raising this treatment were allowed and the impugned additions were set aside.
Dispute concerns revenue recognition where the assessing officer treated finished goods/advances as sales despite the assessee following the project completion method. The tribunal found that the amounts were offered to tax in subsequent assessment years and taxed on profits thereon, making the AO's estimate result in double taxation; accordingly the addition treating such stock/advances as turnover was deleted. Reliance on precedents supporting deletion where income is taxed in later years was noted. Resultantly, all grounds of appeal raising this treatment were allowed and the impugned additions were set aside.
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