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    <title>2025 (6) TMI 397 - ITAT COCHIN</title>
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    <description>Reassessment under section 148 was upheld because the legal challenge to reopening failed, and the additions linked to project advance were sustained because income recognition had already commenced with the start of work under the assessee&#039;s accounting method. The Tribunal followed the co-ordinate Bench decision in the assessee&#039;s own case and held that part of the project cost could properly be treated as income from the stage when project execution began. On both the reopening issue and the merits of the attribution of profits, the appeals failed and the assessment as affirmed by the first appellate authority remained undisturbed.</description>
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      <description>Reassessment under section 148 was upheld because the legal challenge to reopening failed, and the additions linked to project advance were sustained because income recognition had already commenced with the start of work under the assessee&#039;s accounting method. The Tribunal followed the co-ordinate Bench decision in the assessee&#039;s own case and held that part of the project cost could properly be treated as income from the stage when project execution began. On both the reopening issue and the merits of the attribution of profits, the appeals failed and the assessment as affirmed by the first appellate authority remained undisturbed.</description>
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