9911796707
TMI Blog2019 (5) TMI 414X X X X Extracts X X X X X X X X Extracts X X X X ..... act and in the circumstances of the case and in law the Ld. CIT(A) has erred in deleting the addition of Rs. 1,86,61,354/- made by the A.O. being 8 % of total Work In Progress(WIP) shown in books of the assessee ignoring the fact that projects undertaken by the assessee were at the stage of completion and no sale or opening/closing of WIP were shown by the assessee in P & L, A/c. for the year under consideration. 2. On the facts and in the circumstances of the case and in law the Ld. CIT(A) has erred in holding that assessee has offered income of Rs. 51,22,961/- in the A.Y. 2003-04 earned from the projects undertaken adopting Completion Contract Method (CCM) and the assessee has liberty to choose either PCM or CCM as per desire ignoring the fact that assessee had tried to evade the taxes by not showing income at all form sale of flats till the year under consideration. 3. The Ld. CIT(A) erred in law as well as on fact by applying the Hon'ble Supreme Court judgment in the case of Hyundai Heavy Industries Co. Ltd. [2007] 161 Taxman 191 (SC) and other decision in favour of assessee wherein the facts are entirely different from the case under consideration. 4. The appellan ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ent order passed u/s.143(3) for assessment year 2001-2002 in which return was filed declaring Nil income and the same was assessed as such, meaning thereby that the work in progress was allowed to continue without considering it to be completion M/s.Sea Sagar Construction Co. of project. For assessment year 2003-2004, the assessee furnished return declaring income of Rs. 51,96,112. It is the case of the assessee that in this year the contract got completed and following project completion method the assessee offered income for taxation in such year. Copy of profit and loss account and balance sheet for assessment year 2003-2004 has been placed on record from where it can be seen that income has been shown to the credit side of the profit and loss account from the contract and there is no work in progress in the balance sheet for the said year. It, therefore, transpires that following the project completion method the assessee offered income in respect of these projects in assessment year 2003-2004 which has been accepted by the Revenue. Once the income is taxed in assessment year 2003-2004 on the completion of the project, there cannot be any question of taxing the same amount in t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ppeal revolves around whether any income on the work-in-progress on construction work carried out by the assessee is chargeable to tax in the impugned assessment year . The assessee had shown work in progress in its books of accounts of Rs. 23.33 crores but the assessee did not offer any income on the WIP declared by it in its books of accounts. Simultaneously, the assessee was showing advance received against booking of the flats which were been constructed by the assessee in its books of accounts. Thus in the opinion of the AO the income on the work in progress being flats under construction was not declared by the assessee in the return of income filed with Revenue while the main contention of the assessee is that it is following completed contract method and the entire income of the projects undertaken by the assessee has been duly declared in the AY 2003-04 wherein total income of Rs. 51,22,966/- stood declared in the return of income filed with Revenue and due taxes stood paid to Revenue on this project. The assessee is following mercantile system of accounting. The assessee is a partnership firm having two partners namely Mayuresh Builder and M/s Satlej Properties Private Li ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the same is to be brought to tax in the impugned assessment year on accrual basis in compliance with directions of the tribunal vide appellate orders dated 24.11.2010 in ITA no. 789/Mum/ 2009. The AO was of the view that the assessee has perpetrated fraud on Revenue and gross misrepresentations were made before the tribunal in first round of litigation. The assessee has claimed that it is following completed contract method of accounting and no income accrued to it as per AS-7(un-amended) issued by ICAI. The AO observed that 85% of the project is complete by the end of the previous year relevant to impugned assessment year and hence income is to be brought to tax in this year also. The AO was of the view that since in the earlier years no income was declared , then in this impugned assessment year income to the tune of 8% of work in progress needs to be brought to tax. The assessee on its part pleaded that learned CIT(A) has held in favour of the assessee in AY 1999-00 and prayers were made by the assessee that provisions of Section 147 of the 1961 Act be not applied. The contentions of the assessee did not found favour with the AO who brought to tax income to the tune of 8% of the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 369,165,351,94 43,832.04 369,209,183.98 Sea Sagar Construction Co. SSC SSC SSC SSC (SSC) FY 00-01 FY-01-02 FY -02-03 Total Work- in -Progress -SB 148,184,666.75 148,184,666.75 Work -in -Progress -SD 109.133,139.68 109,133.139.68 Work- in- Progress -SB-SD 883.097,00 7,075,500.00 13,870,195.00 21,828,792.00 Sea Breeze Shopping 4,581,881.50 4.581,881.50 Sagar Darshan Shopping 4,084,752.50 4,084,752.50 Sea Breeze CHS Ltd .43,099,018.60 43,099,018.60 Sagar Darshan CHS Ltd. 38,296,932.95 38,296,932.95 (445,701,00) 445,701.00 90,499,981.55 70,75,500.00 271,633,702.43 369,209,183.98 Revenue Recognised (AY 2003-04) Total (MB+SSC) WIP as above ' 783,880,297 Advance against Reservation 789,003,258 5,122,961 Note: 'SSC' stands for Sea Sagar Construction Company and 'MB' stands for Mayuresh Builder 5.2 The assessee explained before learned CIT(A) that in some places ITAT in its order dated 24.11.2010 has taken WIP figure of Mayuresh Builder ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... under:- Financial year Amount [Rs.] 2000-01 9,04,99, 982 2001-02 70,75,500/- 2002-03 27,16,33,702/- Total 36,92,09,184- 5.3.3 However, the AO observed in its remand report that according to Balance Sheet for the year ending 31.03.1997, the WIP was shown as under: Work-in-progress-Sea Breeze Rs. 14,74,80,448.75 Work-in-progress-Sagar Darshan Rs. 10,89,79,275.68 Work-in-progress-Office Rs. 2,12,78,967.36 Rs. 27,77,38,691.79 5.3.4 The AO observed in its remand report that the assessee has claimed that WIP of Rs. 9,04,99,982/- was transferred from Mayuresh Builder in the Financial Year 2000-01. The AO observed from Balance Sheet for Financial Year 2000-01 that however the WIP-A/c Mayuresh Builder was shown at only Rs. 8,83,096/-. The amount appearing for FY 2001-02 was only Rs. 70,75,500/- . The AO further observed in remand report that for FY 2002-03, the WIP a/c Mayuresh Builder is not at all appearing in the Balance Sheet. Hence, assessee's contention that it had transferred a sum of Rs. 9,04,99,982/- in FY 2000-01 and Rs. 27,16,33,702/ in FY 2002-03 was found by the AO to be not correct. 5.3.5. The AO also observed in its remand rep ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... as bound to declare in AY 2003-04 as per its own contentions that it is following project completion method and taxes were evaded. 5.3.10 The AO observed in remand report that meagre income by way of service charges to the tune of Rs. 51,22,961/- was shown by the assessee in AY 2003-04. The AO observed that substantial work was completed by AY 2000-01 which is evident from advances received and WIP, the income ought to have been declared by the assessee in the impugned assessment year and the AO rightly brought to tax said income by estimating the same @8% of WIP. Thus, the AO submitted in its remand report filed before learned CIT(A) that the assessment order dated 29.12.2011 passed by the AO u/s 143(3) read with Section 254 of the 1961 Act be upheld. It was also submitted by the AO in its remand report that learned CIT(A) is otherwise free to decide the issue on merits. 5.4 The assessee in rejoinder to remand report dated 28.02.2013 submitted before learned CIT(A) reiterated factual background of the case which are not repeated here. It was explained that Mayuresh Builder who was earlier responsible for construction and development of the two societies was also following comp ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... additions to the income of the assessee vide appellate orders dated 15.04.2009 and 13.02.2009 passed by tribunal for those years . It was explained before learned CIT(A) by the assessee that to the best of assessee's knowledge, the Revenue has not challenged said orders of the tribunal before Hon'ble Bombay High Court as no appeal was filed by Revenue u/s 260A before Hon'ble Bombay High Court. 5.4.3. The assessee then referred to tribunal decision in first round of litigation for impugned assessment year 2000-01 and submitted that tribunal accepted completed contract method of accounting followed by the assessee but there was some confusion as to the figure of WIP shown by the assessee and the matter was restored to the AO for limited purpose of ascertaining whether the two projects referred to in assessment year 2000-01 was part of the project completed in AY 2003-04 and income was offered for taxation. 5.4.4 The assessee submitted before learned CIT(A) that the AO in second round of litigation erred in observing that in AY 2000-01 , the work of the project was complete. It was submitted that these two projects were completed in the previous year relevant to AY 2003-04.It was ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... s as on 31.03.2001 and hence it was explained that there is no confusion in the figure of WIP as on 31.03.2001. Thus, it was claimed that if ITAT order for AY 2000-01 in first round of litigation is properly implemented, then income to be assessed for impugned year should be Nil. It is claimed that no other project apart from these two projects namely Sea Breeze and Sagar Darshan were undertaken by the assessee.It was also claimed , without prejudice, that in any case income of the assessee from these two projects was Rs. 51,22,961/- and even if percentage completion method is to be applied, then also the aforesaid income on proportionate basis as is relatable to year under consideration is to be brought to tax for the impugned assessment year and in that situation, appropriate adjustment is to be made while assessing income for AY 2003-04 as otherwise there will be double taxation of the same income which is not permissible. The assessee strongly objected to remarks of the AO that the assessee has evaded taxes. 5.4.8. The AO had also submitted its comments in remand report dated 28.02.2013 in response to paper book filed by the assessee. The assessee gave its replies to the said ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... rom contract which is not justifiable Thus, it was explained that the directions given by ITAT in its order for AY 2000-01 in first round of litigation had not been followed by the AO and hence assessment order dated 29.12.2011 passed by the AO u/s 143(3) read with Section 254 of the 1961 Act is bad in law. 5.4.10 It was submitted that service charges of Rs. 51,22,961/- were infact income from these two projects earned by the assessee which was offered for taxation in AY 2003-04. Our attention was drawn to Notes to accounts of the audited financial statements for AY 2003-04, which are reproduced hereunder: "1. During the year under consideration , the firm has settled accounts with both the societies viz. Sea Breeze Co-op Hsg. Society Ltd. & Sagar Darshan Co-op Hsg. Soc. Ltd. And as per clause of 10 of Article of Agreement dt. 20.07.1993 . The firm has debited the sum of Rs. 39,44,75,676/- Rs. 38,94,04,619/- being cost of building project that includes cost of land, work in progress, finance expenses and all other administrative/maintenance expenses till 30.09.2002. Similarly the firm has credited account of Sea Breeze Co-op Hsg. Society Ltd. & Sagar Darshan Co-op Hsg. Soc. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... (Mum.) 6. CIT v. Khoday Distilleries Ltd (Kar HC) (ITRC Nos. 19 to 21 of 1993, dated 12.9.1995) 7. CIT v. V. S. Dempo & Co. Pvt. Ltd.[1996] (131 CTR 203) (Bombay) 8. CIT v. Vikas Oberoi (165 Taxation 7)(Bombay HC) 9. Awadhesh Builders v. 1TO [2010] (37 SOT 122)(Mum) 10. ACIT v. Rajesh Builders (2004-TI0L-88-ITAT-MUM) 11. ACIT v. Flowmore Pvt. Ltd. [1989] 33 TTJ (Del) 17 12. CIT v. Manju Gupta (RA No. 756/Bombay/94 and RA No. 757/Bom/94 order dated 10th Feb, 1995, Revenue required the Tribunal to refer the following question to Bom HC for its opinion. 13. Malka Construction Co. (ITA No. 4068-4069/Bom/85 dt. 7.3.1989) 14. Super Builders & Developers P. Ltd. (ITA 2080/Bom/1986 dt. 5.6.1990) 15. P.D.R. Pvt. Ltd. (ITA 2704/B/82 dt. 22.1.1983) 16. D.K.Enterprises (ITA 9618/B/1990 dt. 17.7.1991 reported in 39 ITD 394) 17. Davy Power Gas Ltd.(ITA no. 819/Bom) 18. Rajesh Construction (ITAT No. 3592/Bom/95, Order dtd 05.09.2003(Bombay ITAT) 19. Maitri Developers v. ITO (2011-TIOL-472-ITAT-Mum) 6. The Ld. CIT(A) after considering the submissions of the assessee deleted the additions made by the AO vide appellate order dated 12.03.2014, by holding as ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... at the construction work of two societies had been completed during F.Y. 2002-03 (A.Y. 2003-04) and the assessee had received income and had estimated its taxable income for A.Y. 2003-04 at Rs. 52 lakhs approx. and as such no income was estimated for A.Y. 2001-02. ; (vi). A.Y. 2002-03: No income was offered to tax by the appellant in respect of development of two societies. Return was processed u/s 143(1) at Nil income. (vii). A.Y. 2003-04: The appellant claims to have offered the income to tax in respect of development of two societies. Return was processed u/s 143(1) at income of Rs. 51,96,110/- 4.7. In A.Y. 2000-01 under consideration, the Hon'ble ITAT had observed certain discrepancies in the figures of WIP referred in orders for previous assessment years, such that the WIP upto A.Y. 1997-98 was Rs. 36.78 crores, upto A.Y. 2000-01 was Rs. 63.67 crores and upto A.Y. 2001-02 was only Rs. 19.59 crores. It was contended by the departmental representative that there was a possibility of contracts getting completed in the assessment year under consideration and in the next year some new projects might have been taken by the assessee. It was also observed that the WIP for ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ars except the development of said two societies, I feel no justification in going beyond the directions of Hon'ble ITAT and thereby questioning the revenue recognized in A.Y. 2003-04. Further, when the revenue recognized in A.Y. 2003-04 is not to be questioned, there can also be no justification in assessing the revenue for current year on presumptive basis, as it would amount to double taxation. It is also a fact that the appellant's own cases in prior/subsequent years on similar issue have finally decided in favour of the appellant, and hence there is no justification in deviating from the same. 4.11. In view of the above, the addition made of Rs. 1,86,61,354/- in the assessment order is deleted, and the grounds No. 1 to 4 of appeal are allowed." 6.2. Thus, the Ld. CIT(A) restricted its decision based upon directions given by ITAT in its appellate order dated 24.11.2010 in ITA no. 789/Mum/2009 for AY 2000-01 and further it was observed by Ld. CIT(A) that when the income had suffered tax in AY 2003-04 on completion of the two projects, the same cannot be brought to tax in AY 2000-01 as otherwise it will lead to double taxation . In nut-shell, the learned CIT(A) allow ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... he contribution received from members of these societies and the cost of construction and it was submitted that in any case margin of profit of the assessee could not have exceeded 10% of the project cost as per terms of agreement with these societies. It was submitted that M/s. Mayuresh Builders were contractors till June 1997 and they transferred work- in-progress appearing in their books of accounts in three tranches spread in three years starting from FY 2000-01 to 2002-03 to the assessee. It was submitted that accounts were finally settled by the assessee with these two societies in the AY 2003-04 and the surplus of Rs. 51.22 lacs was duly offered to taxation in AY 2003-04. The total contribution received from the members were Rs. 78.89 cores while expenditure towards cost of construction were 78.38 crores, leaving a surplus of Rs. 51.22 lac which was offered to taxation during the AY 2003-04 in the return of income filed with Revenue by following the completed contract method of accounting . It was submitted that the ITAT in first round of litigation set aside the matter to the file of AO after accepting the completed contract method and with direction to reconcile work in pr ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Y 2001-02 in the case of the assessee. The said assessment order is placed in file. It was explained that the AO has noted in assessment order for AY 2001-02 that the assessee carried out construction activities of two societies namely Sea Breeze Co-op. Housing Society and Sagar Darshan Co-op. Housing Society as their power of attorneys and the assessee was entitled for service charges as per agreement entered with these societies. It is stated that the assessee firm is a power of attorney holder of the two societies viz. Sea Breeze and Sagar Darshan and not a contractor or a builder. It is recorded that the assessee gives its professional expertise in completing the construction work of the said societies and the assessee firm is to get its income from the societies subject to surplus in the hands of the societies. It is recorded that the assessee is maintaining its books of accounts on cash basis and there is no income earned on cash basis of accounting. Since gross receipts till previous ended 31.03.2001 were lower than total outgoings of work in progress. It is also recorded in the said assessment order for AY 2001-02 that total outgoings during the year towards WIP was Rs. 19. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ity of funds and downfall in real estate sector, the said Mayuresh Builder could not carry forward the work of construction and development of residential buildings for members of these two societies as it could not arrange for finances required for carrying forward construction work which it was obligated under contractual obligation with these societies. The said Mayuresh Builder was following completed contract basis as method of accounting for booking revenue since 1993 onwards. Since the aforesaid construction and development work was not completed till it continued working i.e. till June 1997 , the said Mayuresh Builder was declaring Nil Income in the return of income filed with Revenue for all these years from 1993 onwards in all these years wherein it continued to carry out construction and development work of residential Buildings for members of these two societies . The expenditure incurred for construction work was recognised as Work-in-Progress in the books of accounts of Mayuresh Builder , while amount received from members of the said societies towards cost of flat was shown as advances received from members in its books of accounts. While framing assessment in the ca ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... in AY 2003-04. The said order of the tribunal and order of Hon'ble Bombay High Court in the case of Mayuresh Builder for AY 1997-98 are placed in file. 9.3 Being unable to carry forward the construction and development of residential buildings for members of these two societies owing to financial constraints and downturn in real estate sector, M/s Mayuresh Builder then entered into partnership with one M/s Satlej Properties Private Limited as partners in June 1997 to form new partnership firm namely M/s Sea Sagar Construction Company viz. the assessee and the construction agreements with these two societies were assigned to the assessee in June 1997 to carry forward construction and development work for the members of these two societies. 9.4 The assessee also adopted completed contract method of accounting consistently since its formation in June 1997 viz. previous year relevant to AY 1998-99 & onwards to book its revenue. The expenditure incurred for construction and development of residential buildings for the members of these two societies were debited to Work-in-progress account in books of accounts of the assessee while advances received from members towards flats were s ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... t is categorically and consistently averred by the assessee that its only business activities during all these years since its inception in June 1997 till previous year relevant to AY 2003-04 was to construct and develop the residential buildings for the members of these two societies namely Sea Breeze and Sagar Darshan and no other work/construction/business for any other person was undertaken by it in all these years. It is claimed that the assessee earned Rs. 51,22,963/- from the construction and development work carried out by it for the members of these two societies which was shown as service charges in AY 2003-04 when construction and development stood completed, in accordance with contract with the societies as the assessee was merely contractor and was entitled for profit which was the differential between amount received from members towards flats and the construction expenditure incurred by the assessee, which profit of the assessee in any case could not have exceeded 10% of the project cost as per terms of contract with these societies. It is claimed that since the land belonged to the society for which the assessee was constructing these flats for members of these two ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e for AY 1998-99, the learned CIT(A) has noted in its appellate order dated 12.03.2014 for the impugned assessment year 2000-01 that the AO estimated profit @8% of total receipts being presumptive rate u/s 44AD for AY 1998-99 and on appeal the learned CIT(A) deleted the addition. On further appeal by Revenue, the tribunal restored the matter to file of the learned CIT(A) who again deleted the addition. The tribunal in ITA no. 5285/Mum/2007 vide orders dated 15.04.2009 dismissed the appeal of the assessee. 9.6.2 It is further noted by learned CIT(A) in its appellate order dated 12.03.2014 for impugned assessment year 2000-01, that in AY 1999-00, the assessee again did not offer any income for taxation with respect to construction and development of these two societies . The AO made additions which were deleted by learned CIT(A). 9.6.3 For AY 2001-02 , the learned CIT(A) noted in its appellate order dated 12.03.2014 for impugned assessment year 2000-01, that the AO while framing assessment u/s 143(3) vide order dated 28.03.2003 ( copy placed in file) for AY 2001-02 itself accepted that no income can be brought to tax for AY 2001-02 keeping in view that project was completed in AY ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ations / enquiries to threadbare verify total WIP of Rs. 78.38 crores, expenditure incurred towards construction or amounts received/receivable from members of these two societies of Rs. 78.90 crores vis-a-vis contract entered by the assessee with these two societies to unearth any fraud on Revenue perpetrated by the assessee or any excessive expenditure booked by the assessee towards construction cost or suppression of Income by the assessee.The Revenue did not scrutinised return of income for AY 2003-04 at all rather it was processed only u/s 143(1) of the 1961 Act but now bald statements based on conjectures and surmises are made without any cogent incriminating material on record that the assessee has perpetrated fraud on revenue and that heavy expenditures were claimed by the assessee vis-a-vis budgeted expenses without any basis. If Revenue is making any of such allegations, it was incumbent on Revenue to have brought cogent incriminating material to prove its contentions which unfortunately no such material is brought on record except bald statements. The budged total cost of project by Architect was Rs. 62.50 crores while the actual expenditure was to the tune of Rs. 78.38 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... t has been held that in every case of substitution of one method by another method, the burden is on the Department to prove that the method in vogue is not correct and it distorts the profits of a particular year. Under the mercantile system of accounting based on the concept of accrual, the method of accounting followed by the assessees is relevant. In the present case, there is no finding recorded by the Assessing Officer that the completed contract method distorts the profits of a particular year. Moreover, as held in various judgments, the Chit Scheme is one integrated scheme spread over a period of time, sometimes exceeding 12 months. We have examined computation of tax effect in these cases and we find that the entire exercise is revenue neutral, particularly when the scheme is read as one integrated scheme spread over a period of time." 9.7 This is second round of litigation before us. In the first round of litigation, the AO rejected the completed contract method followed by the assessee and brought to tax income by estimating @15% of WIP of Rs. 23.33 crores. The matter went upto tribunal who was pleased to set aside the matter back to the file of the AO for denovo adjud ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... tion the Assessing Officer is free to decide as per law." 9.7.2 In the second round of litigation, the AO made additions to income by estimating income @8% of the WIP. The learned CIT(A) on the other hand deleted the additions as were made by the AO.The matter is now before tribunal at behest of Revenue. As could be seen from the appellate order of the tribunal in first round of litigation dated 24.11.2010, the tribunal has noted that the tribunal in assessment year 1997-98 has recorded a categorical finding that the total work done upto assessment year 1997-98 was Rs. 36.78 crores. This WIP upto 31.03.1997 was recorded by tribunal at page 8/para 11 in its order dated 18.01.2005 in ITA no. 648/Mum/2001 for AY 1997-98 in the case of Mayuresh Builder. The said order is placed in file. The assessee has contended that M/s Mayuresh Builder did incurred expenditure to the tune of Rs. 36.78 crores on construction till 31.03.1997 which was shown in books of accounts under the head WIP in books of accounts of Mayuresh Builders and total sum of Rs. 36.92 crores was incurred towards construction by Mayuresh Builder till 31.03.2000 which was reflected in WIP in books of accounts of Mayuresh ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 7 783,880,297 9.7.4 Thus, as could be seen above that Rs. 60.25 crores was the combined WIP as is existing in the books of accounts of Mayuresh Builders and the assessee firm as at 31.03.2000. This also stood explained by the assessee and it could not be controverted by learned DR. Then , the tribunal recorded in its order dated 24.11.2010 that in AY 2001-02 the WIP was shown at Rs. 19.59 crores , which as could be seen from the above chart is the incremental WIP including expenditure incurred in previous year relevant to AY 2000-01 by the assessee which is recorded in books of accounts of the assessee firm. The Incremental WIP during previous year relevant to AY 2001-02 was Rs. 18,44,80,805/- while expenditure incurred during the year was Rs. 1,14,42,835/- leading to sum total of Rs. 19,59,23,640/- as is recorded in books of accounts of the assessee for the financial year ended 31.03.2001. The said sum of Rs. 18,44,80,805/- recorded as incremental WIP included WIP of Rs. 9,04,99,982/- transferred from the books of accounts of Mayuresh Builders to the books of accounts of the assessee firm in the previous year relevant to AY 2001-02. The factum of outgoings towards incremental ..... X X X X Extracts X X X X X X X X Extracts X X X X
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