2016 (10) TMI 45

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....reshi ) Leave to amend the proposed question of law. 2. In the present Tax Appeal, revenue has raised the following substantial questions of law for our consideration: "(A) Whether the Appellate Tribunal has substantially erred in law and on facts in quashing the revision order under section 263 read with section 143(3) of the Act without appreciating the fact that percentage comple....

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.... erred in law and on facts in not appreciating the fact that when the assessee himself had offered Rs. 3.5 crore as its income following percentage completion method during the course of survey, the assessee was not entitled to adopt project completion method ? (E) Whether the Appellate Tribunal while quashing the order under section 263 read with section 143(1) has erred in law and on fa....

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....er had referred to a sum of Rs. 121.18 crores (rounded off) as representing booking receipts and had added profit at the estimated rate of 8 per cent thereunder. The Tribunal noted booking receipts were only worth Rs. 22.42 crores (rounded off) on which the assessee had already offered tax at the rate of 8 per cent. The Commissioner therefore, was factually wrong in making further additions on thi....