2024 (11) TMI 218
X X X X Extracts X X X X
X X X X Extracts X X X X
....his appeal is aggrieved by the action of the ld. CIT(A) in confirming the addition made by the Assessing Officer of Rs. 16,47,19,380/- by making assessment of the income of the assessee applying percentage completion method as against the plea of the assessee that it has been regularly following project completion method. 3. The brief facts of the case are that the assessee is a partnership firm and is engaged in the business of builders and developers. During the year, the assessee company had undertaken two projects i.e. 1. Mayfair Greenwoods, 2. Mayfair Elite. The assessee has been following 'project completion method' of accounting, where the income is offered to tax on completion of the project. Further, the assessee firm had executed....
X X X X Extracts X X X X
X X X X Extracts X X X X
....ion to this, the Central Government exercising power u/s 145(2) has notified Income Computation and Disclosure Standards ('ICDS') III vide Notification No.S.O 3079(E) dated 29.09.2016 relating to construction contracts. The Assessing Officer observed that as per the said ICDS III notified by Central Government, the assessee was supposed to disclose its income as per percentage completion method. He observed that in this case, the assessee was nearby to completion of projects as the assessee incurred 84.28% & 67.34% of total cost of project of Mayfair Greenwood project & Mayfair Elite project respectively. Further, the assessee executed agreement for sale for 52870 unit area out of 77920 unit area i.e. 67% and 23270 unit area out of 59310 un....
X X X X Extracts X X X X
X X X X Extracts X X X X
....ring the period from 01.04.2011 to 31.03.2013. He, accordingly, assessed the income of the assessee as per percentage completion method and made the impugned addition. 4. Being aggrieved by the said order of the Assessing Officer, the assessee preferred appeal before the CIT(A), however, the same was dismissed by the CIT(A). 5. We have heard the rival contentions and gone through the record. At the outset, the ld. Counsel for the assessee has submitted that the assessee-firm since inception of its business from the year 1995 has been consistently and regularly following project completion method of accounting. The ld. Counsel has further demonstrated that so far as the observation of the Assessing Officer that for the financial years 2011....