https://www.taxtmi.com/caselaws?id=449774 ITAT Mumbai allowed assessee's appeal against PCIT's revision order u/s 263. PCIT held AO's assessment order was erroneous for not examining revenue recognition method and TDR expenses treatment. ITAT found AO had adequately verified assessee followed percentage completion method, not project completion method as claimed by PCIT. Supporting documents including audit reports and project-wise details were on record. AO had consistently verified this method in previous assessment years. Regarding TDR expenses, ITAT held treating them as capital expenditure was unjustified since TDR represented construction rights forming part of stock-in-trade. PCIT failed to substantiate how assessment order was erroneous and prejudicial to revenue. However, ITAT confirmed PCIT's jurisdiction u/s 263 over faceless assessment orders after record transfer to jurisdictional AO. en-us Fri, 09 Feb 2024 00:00:00 +0530 Tue, 20 Feb 2024 08:31:39 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=449774 ITAT Mumbai allowed assessee's appeal against PCIT's revision order u/s 263. PCIT held AO's assessment order was erroneous for not examining revenue recognition method and TDR expenses treatment. ITAT found AO had adequately verified assessee followed percentage completion method, not project completion method as claimed by PCIT. Supporting documents including audit reports and project-wise details were on record. AO had consistently verified this method in previous assessment years. Regarding TDR expenses, ITAT held treating them as capital expenditure was unjustified since TDR represented construction rights forming part of stock-in-trade. PCIT failed to substantiate how assessment order was erroneous and prejudicial to revenue. However, ITAT confirmed PCIT's jurisdiction u/s 263 over faceless assessment orders after record transfer to jurisdictional AO. Case-Laws Income Tax Fri, 09 Feb 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=449774