Landowner revenue share in JDA: income recognition only on registered sale deed; percentage completion method addition disallowed

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....Whether income from a landowner's revenue share under a JDA accrued by applying the percentage completion method was examined. It was held that revenue cannot be recognized until significant risks and rewards pass, which in case of immovable property occurs only upon execution and registration of the sale deed; mere agreements to sell or advance bookings do not effect transfer or accrual, and advances remain liabilities until possession and registered conveyance. As the landowner had only licensed development through a power of attorney, and consistently followed the project completion method, the tax authority could not mandate the percentage completion method merely because the developer used it. Accordingly, the addition for accrued income was rejected. - ITAT....