TaxTMI 
TaxTMI 
2025 (6) TMI 1862
X X X X Extracts X X X X
X X X X Extracts X X X X
....AC"), Delhi vide order dated 14.06.2024 passed for A.Y. 2017-18. 2. The Assessee has taken the following grounds of appeal:- "1.1 The order passed by u/s.250 passed on 14.06.2024 by NFAC, [CIT(A)], Delhi (for short CIT(A)" upholding the addition of Rs. 4,66,86,192/- made by A.O. towards the alleged difference in receipts as per 26AS statement and profit and loss account is wholly illegal, unlawful and against the principles of natural justice. 2.1 he ld. CIT(A) has grievously erred in law and or on facts in not appreciating that the appellant had fully explained the alleged difference as evident from the written submission dtd. 22.05.2024 reproduced in the impugned order which has not been fully and properly considered ....
X X X X Extracts X X X X
X X X X Extracts X X X X
....ear. In response to notice issued by the Assessing Officer, the assessee submitted that during the impugned assessment year, the assessee has adopted a policy to defer it's income recognition. The difference in the receipts in Profit & Loss Account and the amounts appearing in Form 26AS is on account of deferred revenue recognition. The assessee submitted that during the year, the assessee has adopted an accouting policy to defer the income recognition in respect of three projects since the "ultimate collection with reasonable certainty was lacking". The assessee submitted that during the impugned Financial Year, Larsen & Toubro submitted it's request to grant relaxation and extension in respect of payment of additional concessional premium....
X X X X Extracts X X X X
X X X X Extracts X X X X
....e, the assessee has not demonstrated the reasons for uncertainty of ultimate revenue collection and has also failed to demonstrate, with supporting evidences that the conditions mentioned in AS-9 are fulfilled. Accordingly, Ld. CIT(A) dismissed the appeal of the assessee with the following observations: "I have considered the facts of the case and submission filed by the appellant carefully. I find from para 9.2 of the AS9 that where the ability to assesse the ultimate collection with reasonable certainty is lacking at the time of raising any claim i.e. for escalation of price, export incentives, interest etc. the revenue is postponed to the extent of uncertainty involved. It is further mentioned in the para 9.2 of AS9 that where t....
X X X X Extracts X X X X
X X X X Extracts X X X X
....ons put forth by the appellant are not as per the para 9.2, 10, 11 & 12 of the AS9 for deferring the revenue. Therefore the explanation submitted by the appellant is not found acceptable. Further I find that the facts of the case laws relied upon by the appellant are not identical to the facts of the present case, hence the contention of the appellant is not found acceptable. In view of the above discussion, the ground of appeal raised by the appellant is dismissed." 5. The assessee is in appeal before us against the aforesaid order passed by Ld. CIT(A). Before us, the Counsel for the assessee primarily reiterated the arguments taken before the Lower Authorities. The Counsel for the assessee submitted that the deferment of revenue recogn....