2020 (12) TMI 932

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..... ompletion method to the Project completion method by filing a revised return. It is not the case of the Revenue that the revised return was otherwise, not valid. Similarly, the Revenue has also not made out a case that the assessee did not consistently follow the Project completion method in the following years. AR vehemently submitted that the assessee continued to follow the Project completion method and offered income under this method in the later years. Once it is seen that the assessee switched over from the Percentage completion method to the Project completion method in a bona fide manner and continued with the changed method in the years to come, in our considered opinion, no fault can be found with the ld. CIT(A) deleting the a .....

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..... viewed the statistics from all the four projects undertaken by the assessee in the original return as well the revised return by tabulating details at pages 3 and 4 of the assessment order. On being called upon to explain as to why the method of accounting was changed, the assessee submitted that there were certain unforeseen circumstances, because of which the work in respect of projects had totally stopped. It was also stated that there were certain Court cases against the assessee and it was not able to proceed with the projects. In addition, there were stated to be certain problems with the bankers. This, as per the assessee, led it to adopting the Project completion method by offering profit in respect of sale of flats only on complet .....

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..... e completion method by valuing the closing work-in-progress at estimated realizable price. Certain unforeseen circumstances developed. The assessee switched over from the Percentage completion method to the Project completion method by filing a revised return. It is not the case of the Revenue that the revised return was otherwise, not valid. Similarly, the Revenue has also not made out a case that the assessee did not consistently follow the Project completion method in the following years. The ld. AR vehemently submitted that the assessee continued to follow the Project completion method and offered income under this method in the later years. Once it is seen that the assessee switched over from the Percentage completion method to the Pro .....

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