LAYER EXPORTS P. LTD,MUMBAI vs. ACIT CEN CIR 21, MUMBAI
In the result, the appeals of the Revenue and that of the assessee are decided as indicated above against each issue
ITA 3378/MUM/2016[2011-12]Status: DisposedITAT Mumbai31 Oct 2016AY 2011-12
Bench: Sri Mahavir Singh, Jm & Sri B. R. Baskaran, Am
Section 132
…d any material on record to the contrary. He has only given a finding as regards completion based on conjectures and surmises. 48. Before us reliance was placed on the decision of co-ordinate bench of Mumbai in the case of ITO Vs. Pratiksha Enterprises (2008) 4 DTR 547 (Mum), wherein the dispute was for determination of the year of completion of the project in a case where the assessee is following project completion method. The assessee had offered the income in AY 2003-04 whereas the Department had given a finding that the project was competed in AY 2002-03. The assessee had filed a certificate of Architect sho…