https://www.taxtmi.com/caselaws?id=783054 ITAT Bangalore dismissed Revenue's appeals and allowed assessee's appeal. It upheld CIT(A)'s deletion of additions treating amounts received under a joint development agreement as business receipts taxable on receipt, holding that, in absence of valid seized material in search-based assessments u/s 143(3) r.w.s. 153D, sworn statements alone cannot sustain additions. It affirmed that income from sale of flats received under the development agreement is taxable in the year of execution of sale deeds, not on receipt of advances. On interest disallowance, ITAT held the borrowing and interest to be genuine and wholly for business, and that disallowance based only on the AO's preferred accounting method, causing mere timing distortion without revenue impact, is impermissible; the Rs. 3.08 crore addition was deleted. en-us Fri, 28 Nov 2025 00:00:00 +0530 Tue, 09 Dec 2025 08:41:58 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=783054 ITAT Bangalore dismissed Revenue's appeals and allowed assessee's appeal. It upheld CIT(A)'s deletion of additions treating amounts received under a joint development agreement as business receipts taxable on receipt, holding that, in absence of valid seized material in search-based assessments u/s 143(3) r.w.s. 153D, sworn statements alone cannot sustain additions. It affirmed that income from sale of flats received under the development agreement is taxable in the year of execution of sale deeds, not on receipt of advances. On interest disallowance, ITAT held the borrowing and interest to be genuine and wholly for business, and that disallowance based only on the AO's preferred accounting method, causing mere timing distortion without revenue impact, is impermissible; the Rs. 3.08 crore addition was deleted. Case-Laws Income Tax Fri, 28 Nov 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=783054