S. B. PATEL INFRASTRUCTURE PRIVATE LIMITED,VADODARA vs. THE ITO, WARD-2(1)(3) NOW THE DY. CIT, CIRCLE-2(1)(1), VADODARA

ITA 78/AHD/2023Status: DisposedITAT Ahmedabad08 September 2026AY 2014-1514 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the project completion method is a recognized accounting practice and the AO's rejection of books lacked cogent evidence. The additions made on account of alleged undisclosed receipts were based on inference rather than concrete proof.

What were the facts?

The assessee, engaged in real estate development, followed the completed contract method of accounting. The Assessing Officer (AO) rejected the books of accounts due to the accounting method and variations in sale agreements for identical flats, making additions based on estimated profit and undisclosed receipts.

What were the issues?

Whether the rejection of books of accounts and subsequent additions made by the AO were justified based on the accounting method and variations in sale agreements.

Which sections of the Income-tax Act were involved?

Section 145,Section 144

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, “A” BENCH, AHMEDABAD

Before: SHRI NARENDRA PRASAD SINHA & SHRI TAPAS RAM MISRA

For Appellant: Shri Mehul K. Patel, Advocate
For Respondent: Shri Amit Pratap Singh, SR-DR
Hearing: 13.08.2026Pronounced: 08.09.2026

PER NARENDRA PRASAD SINHA, ACCOUNTANT MEMBER:

These two appeals are filed by the Assessee against separate orders of National Faceless Appeal Centre (NFAC), Delhi [hereinafter referred to as “CIT(A)”] both dated 12.12.2022 for the Assessment Years (A.Y.) 2014-15 and 2015-16 in the proceeding u/s 143(3) of the Income Tax Act [hereinafter referred as “the Act”]. As the issues involved and the grounds taken by the assessee in the two appeals were identical, both the matters were heard together and are being disposed of vide this common order for the sake of c

The order continues below.

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