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    <title>2025 (12) TMI 1509 - ITAT GAWAHATI</title>
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    <description>The dominant issue was whether the AO could reject the assessee&#039;s consistently followed project completion method and compel percentage completion merely because sales exceeded the 25% threshold under ICAI guidance. Since the assessee had offered the same flat-sale revenue to tax in subsequent years on completion in line with AS-9, adopting percentage completion for the year would cause impermissible double taxation, and consistency principles (SC) barred a changed stance absent changed facts; the deletion of the revenue addition was upheld. A further issue concerned disallowance of interest under s. 36(1)(iii) r/w s. 40A(2)(a) on dealings with a related party; as no interest was claimed in P&amp;L and the interest was capitalised to work-in-progress, the disallowance was untenable and was reversed, dismissing the Revenue&#039;s appeal.</description>
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    <pubDate>Thu, 18 Dec 2025 00:00:00 +0530</pubDate>
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      <link>https://www.taxtmi.com/caselaws?id=783969</link>
      <description>The dominant issue was whether the AO could reject the assessee&#039;s consistently followed project completion method and compel percentage completion merely because sales exceeded the 25% threshold under ICAI guidance. Since the assessee had offered the same flat-sale revenue to tax in subsequent years on completion in line with AS-9, adopting percentage completion for the year would cause impermissible double taxation, and consistency principles (SC) barred a changed stance absent changed facts; the deletion of the revenue addition was upheld. A further issue concerned disallowance of interest under s. 36(1)(iii) r/w s. 40A(2)(a) on dealings with a related party; as no interest was claimed in P&amp;L and the interest was capitalised to work-in-progress, the disallowance was untenable and was reversed, dismissing the Revenue&#039;s appeal.</description>
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      <pubDate>Thu, 18 Dec 2025 00:00:00 +0530</pubDate>
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