2017 (2) TMI 682

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..... For Assessment Year 2007-08, it had reported its transactions in its return which were accepted in scrutiny assessment under Section 143(3) of the Act. The A.O. noted that the Assessee provided maintenance services such as housekeeping, security services, etc. and it accepted the returned income without any disallowance. Later the CIT(A) issued notice under Section 263 of the Act alleging that `11.98 crores was shown as deferred revenue income by changing the method of accounting as per Accounting Standard (AS) -7, and it has resulted in lowering of profit. The CIT(A) finally made an order revising the assessment as erroneous and prejudicial to the revenue, and remitted the matter for consideration to the A.O. The ITAT allowed the assesse....

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....ment Years i.e. annual accounts and assessment orders for Assessment Year 2008- 09, 2009-10, it is amply clear that the assessee consistently followed AS-7 for recognition of revenue which was changed w.e.f. 1.4.2006. 16. It is relevant to mention that the assessment proceedings were completed under Section 143(3) of the Act on 15.12.2009 and the CIT issued impugned order u/s 263 of the of the Act on 12.3.12 and impugned order was passed on 27.3.12 and entire proceedings of issuance of notice and passing order were completed within 15 days time. We further observe that in response to the show cause notice u/s 263 of the Act, the assessee filed detailed written submissions spread over 5 pages on 26.3.12 along with a Paper Book and the CIT h....