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    <title>2026 (1) TMI 177 - ITAT MUMBAI</title>
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    <description>Where an assessee had consistently applied the Project Completion Method for revenue recognition and the Department had accepted it in earlier years, the AO could not unilaterally substitute the Percentage Completion Method in the impugned year absent any change in facts or law; the consequential addition for alleged undisclosed project profit was rightly deleted. An addition founded solely on a statement recorded u/s 131/133A, without corroborative evidence, was held unsustainable; the deletion was upheld. Further, the first proviso to s. 43CA(1) introducing a 10% safe harbour was treated as curative and applied retrospectively; since the stamp valuation variation was 7%, the s. 43CA addition was deleted. Revenue&#039;s appeal was dismissed.</description>
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    <pubDate>Mon, 13 Oct 2025 00:00:00 +0530</pubDate>
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      <title>2026 (1) TMI 177 - ITAT MUMBAI</title>
      <link>https://www.taxtmi.com/caselaws?id=784421</link>
      <description>Where an assessee had consistently applied the Project Completion Method for revenue recognition and the Department had accepted it in earlier years, the AO could not unilaterally substitute the Percentage Completion Method in the impugned year absent any change in facts or law; the consequential addition for alleged undisclosed project profit was rightly deleted. An addition founded solely on a statement recorded u/s 131/133A, without corroborative evidence, was held unsustainable; the deletion was upheld. Further, the first proviso to s. 43CA(1) introducing a 10% safe harbour was treated as curative and applied retrospectively; since the stamp valuation variation was 7%, the s. 43CA addition was deleted. Revenue&#039;s appeal was dismissed.</description>
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      <pubDate>Mon, 13 Oct 2025 00:00:00 +0530</pubDate>
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