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    <title>2026 (4) TMI 483 - ITAT DELHI</title>
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    <description>Statutory notices and repeated opportunities were found to have been issued, with the assessee filing replies; on that record, no procedural infirmity or denial of opportunity was established, so the challenge to the assessment failed. On taxability of contractual receipts reflected in Form 26AS, the Tribunal noted that income must be assessed according to the assessee&#039;s method of accounting, but the assessee did not prove that the receipts had already been offered to tax in earlier years or adjusted through work-in-progress. In the absence of convincing evidence of prior recognition, the receipts were taxed in the year of receipt and the addition was sustained.</description>
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      <link>https://www.taxtmi.com/caselaws?id=789414</link>
      <description>Statutory notices and repeated opportunities were found to have been issued, with the assessee filing replies; on that record, no procedural infirmity or denial of opportunity was established, so the challenge to the assessment failed. On taxability of contractual receipts reflected in Form 26AS, the Tribunal noted that income must be assessed according to the assessee&#039;s method of accounting, but the assessee did not prove that the receipts had already been offered to tax in earlier years or adjusted through work-in-progress. In the absence of convincing evidence of prior recognition, the receipts were taxed in the year of receipt and the addition was sustained.</description>
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