2021 (9) TMI 1462

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....tant Member: The present appeal has been f i led by the assessee against the order of ld. CIT(A)-5, Delhi dated 08.03.2018. 2. Following grounds have been raised by the assessee: "1. The Ld. CIT(A) has grossly erred on facts as well as in law in confirming the assessment order passed by the Ld. AO which is ex-facie illegal, arbitrary and without jurisdiction being against the principles of nat....

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....13 declaring loss of Rs.2,19,39,670/-. 4. It is a fact on record that the assessee has already capitalized Rs.92.75 crores on account of "capital work in progress" in addition to an amount of Rs.13.69 crores under "preoperative expenses" totaling to Rs.106.44 crores. 5. Further, the assessee company has claimed deduction of Rs.2,27,16,104/- on account of expenses deemed to have been revenue in n....

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.... hence resorting to any Accounting Standard cannot negate the taxability of the assessee. 8. Before us, it was argued by the ld. AR that the assessee has already started business operations, construction is in progress and an amount of Rs.106.44 crores has already been capitalized. Hence, it cannot be said that the assessee has not commenced business operations. The expenses being advertising, br....

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....es reflected in the P&L Account. Hence, the matching concept of income to the expenditure is faltered by the assessee. 10. Heard the arguments of both the parties and perused the material available on record. 11. The project cost in relation to a project comprises of cost of land and cost of development rights, borrowing cost, construction and development cost. In relation to land, the entire co....