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“percentage completion method”

ICDS & AccountingICDS IIIICDS III467 judgments

The decision most relied on for percentage completion method is CIT v. Bilahari Investment (P) Ltd. (299 ITR 1), cited in 206 judgments on BharatTax.

Leading authorities on percentage completion method

CIT v. Bilahari Investment (P) Ltd.
299 ITR 1 · 2008 · Supreme Court
206
citing judgments

The project completion method and the percentage of completion method are both recognized methods for recognizing income from real estate contracts.

CIT v. Hyundai Heavy Industries Co. Ltd.
291 ITR 482 · 2007 · Supreme Court
166
citing judgments

The Supreme Court held that the 'project completion method' and the 'percentage of completion method' are recognized accounting methods for ascertaining profit for contracts. The case affirms these methods in the context of contract accounts.

CIT v. ARUN EXCELLO FOUNDATIONS (P) LTD.
212 Taxmann 342 · 2013 · High Court
35
citing judgments

Accounting Standard 7 is not applicable to real estate developers, and therefore, the percentage of completion method cannot be imposed on them. Assessees are justified in following the project completion method as per Accounting Standard 9.

Prestige Estate Projects (P) Ltd. v. DCIT
33 DTR 514 · 2010 · ITAT
28
citing judgments

A real estate developer adopting the completed contract method of accounting cannot be forced to follow the percentage completion method under AS-7 if AS-7 has not been specified by the Central Government under section 145(2). The Assessing Officer cannot reject accounts under section 145(3) solely on this ground.

CIT v. Associated Cables P. Ltd.
286 ITR 596 · 2006 · High Court
25
citing judgments

Retention money withheld by a contractee is not taxable in the year it is retained, but only in the year the obligations under the contract are fulfilled and the amount becomes due to the assessee.

Mazagaon Dock Limited v. JCIT
29 SOT 356 · 2009 · ITAT
25
citing judgments

Anticipated or foreseeable losses on fixed-price construction contracts are deductible in the year the loss is foreseen, aligning with accounting standards like AS-7. This approach is supported by decisions allowing deduction of foreseeable losses based on technical estimation.

Wall Construction Co Ltd. v. JCIT
102 TTJ 505 · 2006 · ITAT
21
citing judgments

Interest expenditure on borrowed funds used for stock-in-trade is allowable as a deduction in the year the revenue is offered to tax, even when following the percentage completion method for recognizing revenue.

CIT v. Aditya Builders
378 ITR 75 · 2015 · High Court
21
citing judgments

The appropriate method of accounting to correctly reflect a true financial statement is a matter of opinion and debate, which is not amenable to revisional jurisdiction under Section 263 of the Act. The Assessing Officer cannot change the method of revenue recognition to the percentage completion method if the assessee has consistently followed the project completion method.

Judgments citing percentage completion method

Sharad Kumar Bhandari, Jaipur vs. DCIT Circle (Intl Tax), Jaipur

ITA 232/JPR/2025[2015-16]Status: DisposedITAT Jaipur13 Aug 2025AY 2015-16
For Appellant: Shri Siddharth Ranka, AdvFor Respondent: Smt. Runi Pal, CIT (through VC)
Section 144C(5)Section 153CSection 69

stated that it would be reasonable to take payment date by assessee in consonance with construction linked revenue recognition of Kothari Group i.e. percentage completion method as adopted by group for real estate project. The relevant portion of AO's observation is reproduced as under: 8. The booking ... construction work in the project progressed till 31.03.2021. Accordingly, revenue from this project was offered by the "Om Kothari Group" as per percentage completion method of computation of income as prescribed for the real estate projects. Therefore, the On-Money pald by the assessee has also been considered

New Laxmi Enterprises, Jogeshwari East, Mumbai vs. The Income Tax Officer, Ward 41(4)(3), Mumbai

In the result, appeal of the assessee is allowed for statistical purposes

ITA 2789/MUM/2025[2017-18]Status: DisposedITAT Mumbai12 Aug 2025AY 2017-18

Bench: Shri Amit Shukla & Shri Girish Agrawalassessment Year: 2017-18 New Laxmi Enterprises The Income Tax Officer, 702, Laxmi Narayan Apartments, Ward 41(4)(3), Mumbai Rane Compound, Natvar Nagar Vs. Road No. 1, Jogeshwari East, Mumbai - 400060 (Pan : Aadfn2479B) (Appellant) (Respondent) Present For: Assessee : Shri Amit Kothari, Ca Revenue : Shri Leyaqat Ali Aafaqui, Sr. Ar Date Of Hearing : 05.08.2025 Date Of Pronouncement : 12.08.2025 O R D E R Per Girish Agrawal: This Appeal Filed By The Assessee Is Against The Order Of Ld. Cit(A), National Faceless Appeal Centre (Nfac), Delhi Vide Order No. Itba/Nfac/S/250/2024-25/1073736005(1), Dated 26.02.2025 Passed Against The Assessment Order By Assessment Officer, Mum-W- (404)(93), U/S. 147/148 Of The Income-Tax Act (Hereinafter Referred To As The “Act”), Dated 21.05.2023 For Assessment Year 2017-18. 2. Grounds Taken By The Assessee Are Reproduced As Under: " 1) The Learned Commissioner Of Income Tax (Appeals) Ered In Upholding The Addition Of Rs. 1,58,23,513 Without Appreciating The Fact That The Appellant Is A Builder & The Flats Sold Were Stock In Trade Which Is Chargeable To Tax Under The Head Business Income & Not Capital Gains. 2) The Learned Commissioner Of Income Tax (Appeals) Ought To Have Considered That Out Of The Addition Of Rs 1,58,23,513, Sale Value Of Flats Of Rs. 1,56,42,514

For Appellant: Shri Amit Kothari, CAFor Respondent: Shri Leyaqat Ali Aafaqui, Sr. AR
Section 147Section 148Section 43CSection 44ASection 50C

return of income on 02.12.2017 reporting total income at Rs. 1,75,660/- as income from business on sale of flats by following percentage completion method. Case of the assessee was reopened by issuing notice u/s. 148 by applying provisions of Section 50C. According to the assessee, it follows percentage

ACIT, Cir-1(1), Rajkot vs. Shri Rajkot District Co Operative Bank Ltd, Rajkot

The appeal of the revenue is dismissed

ITA 188/RJT/2024[2015-16]Status: DisposedITAT Rajkot05 Aug 2025AY 2015-16

Bench: Dr. Arjun Lal Saini. & Shri Dinesh Mohan Sinhaआयकरअपीलसं./Ita No.188/Rjt/2024 िनधा"रणवष"/ Assessment Year: (2015-16) (Hybrid Hearing) Assistant Commissioner Of Income- Vs. Rajkot District Co-Operative Bank Tax, Circle-1 (1), Rajkot Limited Room No.502, Aayakar Bhawan, Jilla Bankbhavan, Kasturba Road, Race Course Ring Road, Rajkot- Opp: Chaudhary High School, 360001 Rajkot 360001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaaar0564K (Appellant) (Respondent) Appellant By : Shri D. M. Rindani, Ld. Ar Respondent By : Shri Abhimanyu Singh Yadav, Ld.Sr.Dr : 09/06 /2025 Date Of Hearing Date Of Pronouncement : 05/08 /2025

For Appellant: Shri D. M. Rindani, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld.Sr.DR
Section 143(3)Section 36(1)Section 36(1)(viii)

been accepted by department in assessment year 2014-15, principle of consistency should be followed; Assessing Officer was not justified in adopting percentage completion method for A.Y. 2015-16” 10. The Ld. DR further submitted that Section 36(1)(viii) of the Income Tax Act, 1961, allows specified entities engaged

Dosti Realty Limited, Mumbai vs. DCIT, Circle-1(1)(1), Mumbai

In the result, appeal of the assessee is partly allowed

ITA 6128/MUM/2024[2015-16]Status: DisposedITAT Mumbai31 Jul 2025AY 2015-16

Bench: Shri Saktijit Dey, Hon'Ble & Shri Girish Agrawalassessment Year: 2015-16

For Appellant: Shri Vijay Mehta, CAFor Respondent: Shri Annavaran Kosuri, Sr. DR
Section 143(3)Section 14ASection 37(1)

prejudice to the above and without admitting, Ld CIT(A) erred in assuming that 91% of the project is completed whereas as per percentage completion method only 64.29% is completed. 3. Disallowance of legal and professional fees of Rs. 61,79,780/- a. On facts and circumstances of the case ... allowance towards 11 Dosti Realty Ltd. Assessment Year 2015-16 brokerage and commission expenses claimed by the assessee in the context of percentage completion method adopted by the assessee. Hon'ble Court held in favour of the assessee to allow the expenses towards brokerage and commission as revenue in nature

Deputy Commissioner of Income Tax, Circle-7(1)(1), Bangalore vs. M/S Elegant Builders and Developers, Bangalore

In the result, the appeal of the assessee is partly allowed

ITA 1679/BANG/2024[2018-19]Status: DisposedITAT Bangalore21 Jul 2025AY 2018-19

Bench: Shri Prashant Maharishi & Shri Soundararajan K.Assessment Year: 2018-19

For Appellant: Shri Chaitanya K. K., Senior AdvocateFor Respondent: Smt. Srinandini Das, CIT(DR)(ITAT), Bengaluru
Section 142(1)Section 143(3)

also had been accounted for sale. Assessee has maintained its books of accounts and revenue was recognized on Percentage Completion Method and during the year 47 % of The project is completed. However, the ld. AO noted that for AY 2016- 17 itself, the assessee has shown the percentage completion ... sale agreement value of area sold in FY 2017-18. 5. The ld. AO held that assessee has submitted that it is following Percentage Completion Method, however in AY 2016-17 it stated that it follows Project Completion Method. In the case of Embassy Valley it was earlier submitted that

M/S. Elegant Builders and Developers, Bangalore vs. Deputy Commissioner of Income Tax, Circle-7(1)(1), Bangalore

In the result, the appeal of the assessee is partly allowed

ITA 1240/BANG/2024[2018-19]Status: DisposedITAT Bangalore21 Jul 2025AY 2018-19

Bench: Shri Prashant Maharishi & Shri Soundararajan K.Assessment Year: 2018-19

For Appellant: Shri Chaitanya K. K., Senior AdvocateFor Respondent: Smt. Srinandini Das, CIT(DR)(ITAT), Bengaluru
Section 142(1)Section 143(3)

also had been accounted for sale. Assessee has maintained its books of accounts and revenue was recognized on Percentage Completion Method and during the year 47 % of The project is completed. However, the ld. AO noted that for AY 2016- 17 itself, the assessee has shown the percentage completion ... sale agreement value of area sold in FY 2017-18. 5. The ld. AO held that assessee has submitted that it is following Percentage Completion Method, however in AY 2016-17 it stated that it follows Project Completion Method. In the case of Embassy Valley it was earlier submitted that

Richa India Infra Development Private Limited, Mumbai vs. Deputy Commissioner of Income Tax, Circle 8(1)(1), Mumbai

The appeal of the assessee is allowed for statistical purposes

ITA 1622/MUM/2025[2017-18]Status: DisposedITAT Mumbai18 Jul 2025AY 2017-18

Bench: Shri Amit Shukla, Jm & Ms Padmavathy S, Am

For Appellant: Shri Kumar Kale, AdvocateFor Respondent: Shri Annavaran Kosuri, Sr. DR
Section 250Section 43C

full value of consideration under the provisions of section 43CA of the Act. The AO further held that since the assessee is following percentage completion method for revenue recognition why an addition of Rs. 20,21,31,162 cannot be made by reducing work-in-progress. After considering the various ... Since the assessee has not recognized the revenue during the year under consideration on the ground that it is following percentage completion method and the project was completed less than 25%, this differential amount is being reduced from the Work-in-progress to get the beneficial interest when the assessee

A.C.I.T Circle-2(1), Rajkot vs. Sanskar Developers, Rajkot

In the result, the appeal filed by the Revenue is allowed for statistical purposes, whereas cross objection (CO ) filed by the assessee is dismissed

ITA 242/RJT/2024[2015-16]Status: DisposedITAT Rajkot17 Jul 2025AY 2015-16

Bench: Dr. Arjun Lal Saini. & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita No. 242/Rjt/2024 (िनधा"रण वष"/Assessment Year: (2015-16) Assisstant Commissioner Of Income- Sanskar Developers Tax, Circle-2(1), Rajkot, Room No. 311, Shop No. 1, Shri Raj Complex, 1- Vs. 3Rd Floor, Aayakar Bhawan, Race Madhav Park, B/H. Vijay Hostel, Course Road, Rajkot – 360001 150Ft Ring Road, Rajkot – 360004 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Ackfs 2310 R (अपीलाथ"/Appellant) (""यथ"/Respondent)

For Appellant: Shri Rashmin Vakariya, Ld. ARFor Respondent: Shri Sanjay Punglia, Ld. CIT(DR)
Section 147Section 148Section 250

assessee submitted that ICDS III is not applicable to real estate developers and the assessee is not required to follow the percentage completion method. The assessee further submitted before ld.CIT(A) that even the ICDS III, is not applicable to it. The assessee had submitted the computation of net profit ... assessee. During the course of appellate proceedings, the assessee has submitted, before learned CIT( A) that assessing officer has estimated profit on percentage completion method and again made addition on account of understated closing stock. The assessee by relying on the decision of Jurisdictional High Court in the case

Patel Oswal Housing, Pune vs. Addl. CIT (A) - 4, Kolkata

In the result, appeal of the assessee is allowed

ITA 957/PUN/2025[2016-17]Status: DisposedITAT Pune16 Jul 2025AY 2016-17

Bench: Dr.Manish Borad

For Respondent: Appellant by Shri Tarak Trivedi
Section 142(1)Section 143(3)Section 250

Rs.9,79,600/- have been debited to the Profit and Loss Account and that the revenue has been recognised on the basis of Percentage Completion Method (PCM) and 2 Patel Oswal Housing income has been offered to tax. Therefore, the impugned disallowance deserves to be deleted. 4. On the other ... Departmental Representative vehemently argued supporting the orders of the lower authorities and also submitted that if the assessee has recognised the revenue on Percentage Completion Method, then it would also have estimated the expenses. Further ld. Departmental Representative also submitted that the Stamp duty and Registration expenses are not appearing

Kavya Kcd Developers, Mumbai vs. Income Tax Officer, Ward 33(2)(2), Mumbai

In the result, is dismissed;

ITA 5470/MUM/2024[2017-2018]Status: DisposedITAT Mumbai15 Jul 2025AY 2017-2018

Bench: Shri Anikesh Banerjee & Smt. Renu Jauhri- A.Y. 2018-19 - A.Y. 2017-18

For Appellant: Shri Satish ModyFor Respondent: Shri Hemanshu Joshi (SR. DR.)
Section 143(3)Section 144BSection 250

against the 30% of Rs. 3,77,09,150/-, done by AO, which represented WIP added during the year while following percentage completion method. 2. On the facts and circumstances of the case and in law, the Ld. CIT (A) erred in deleting the addition ... declared nil. On the other hand, the Ld.AO in assessment proceedings, changed the method of revenue recognition and calculated the revenue under percentage completion method. Accordingly, the Ld.AO rejected the 30% of the cost project and added back with the total income. Similarly, the interest on the loan is also

Kavya Kcd Developers, Mumbai vs. Naational E Assessement Centre, Mumbai

In the result, is dismissed;

ITA 5469/MUM/2024[2018-2019]Status: DisposedITAT Mumbai15 Jul 2025AY 2018-2019

Bench: Shri Anikesh Banerjee & Smt. Renu Jauhri- A.Y. 2018-19 - A.Y. 2017-18

For Appellant: Shri Satish ModyFor Respondent: Shri Hemanshu Joshi (SR. DR.)
Section 143(3)Section 144BSection 250

against the 30% of Rs. 3,77,09,150/-, done by AO, which represented WIP added during the year while following percentage completion method. 2. On the facts and circumstances of the case and in law, the Ld. CIT (A) erred in deleting the addition ... declared nil. On the other hand, the Ld.AO in assessment proceedings, changed the method of revenue recognition and calculated the revenue under percentage completion method. Accordingly, the Ld.AO rejected the 30% of the cost project and added back with the total income. Similarly, the interest on the loan is also

Vyapti Enterprise, Ahmedabad vs. National E- Assessment Centre Delhi (Jurisdiction the ITO, Ward-3(2)(1)), Ahmedabad

In the result, the appeal filed by the assessee is allowed

ITA 835/AHD/2024[2018-19]Status: DisposedITAT Ahmedabad03 Jul 2025AY 2018-19

Bench: SHRI T.R. SENTHIL KUMAR (Judicial Member), SHRI NARENDRA PRASAD SINHA (Accountant Member)

For Appellant: Shri Dhiren Shah, AR & Ms. Nupur Shah, ARFor Respondent: Shri Rignesh Das, Sr. DR
Section 143(3)

project till the last year of completion of the project. The above contention was not accepted by the Assessing Officer and held that percentage completion method is to be adopted in the assessee’s case since out of the total sale consideration of total units sold ... erred in law and on facts in confirming the addition of Rs. 3,56,16,215/- on account of income estimated by percentage completion method merely on surmises and conjectures. 2. The ld. CIT(A) has erred in law and on facts in not appreciating that the appellant firm recognize

Das Offshore Limited, Mumbai vs. Deputy Commissioner of Income Tax, Circle 1(2), Mumbai

In the result, appeal of the assessee is allowed

ITA 3890/MUM/2023[2012-13]Status: DisposedITAT Mumbai26 Jun 2025AY 2012-13

Bench: Shri Amit Shukla & Shri Girish Agrawalassessment Year: 2012-13 Das Offshore Limited Deputy Commissioner Of Income Sagar Uday, Plot No. F-3, Tax, Circle 1(2), Agroli, Sector 29, Mumbai Behind Cidco Bhawan, Vs. Cbd Belapur, Navi Mumbai - 400614 Maharashtra (Pan: Aaacd5996K) (Appellant) (Respondent) Present For: Assessee : Mr. Fenil Bhatt, Ramesh Jain, Cas Revenue : Shri. Mahadevan A.M. Krishanan, Addl. Cit Date Of Hearing : 22.04.2025 Date Of Pronouncement : 26.06.2025 O R D E R Per Girish Agrawal: This Appeal Filed By Assessee Is Against The Order Of Ld. Cit(A), National Faceless Appeal Centre (Nfac), Delhi, Vide Order No. Itba/Nfac/S/250/2023-24/1055302006(1), Dated 22.08.2023 Passed Against The Assessment Order By Deputy Commissioner Of Income-Tax, Circle 1(2), Mumbai, U/S. 143(3) Of The Income-Tax Act, 1961 (Hereinafter Referred To As The “Act”), Dated 27.11.2017 For Assessment Year 2012-13. 2. Grounds Taken By The Assessee Are Reproduced As Under:

For Appellant: Mr. Fenil Bhatt, Ramesh Jain, CAsFor Respondent: Shri. Mahadevan A.M. Krishanan, Addl. CIT
Section 143(3)Section 147

prescribe by the Institute of the Chartered Accountants of India (ICAI). Assessee has to follow AS-7 for accounting of construction contract wherein percentage completion method is mandated. As per this accounting standard, entity is required to carry out evaluation of all on going contract in year under consideration

Sainath Construction, Mumbai vs. Income Tax Officer Ward 22(3)(1), Mumbai

In the result, the appeal filed by the assessee is allowed for statistical purpose

ITA 2002/MUM/2025[2016-17]Status: DisposedITAT Mumbai23 Jun 2025AY 2016-17

Bench: SHRI VIKRAM SINGH YADAV (Accountant Member), MS. KAVITHA RAJAGOPAL (Judicial Member)

For Appellant: Shri Shreyas Shah, AdvFor Respondent: Shri Leyaqat Ali Aafaqui, SR AR
Section 143(2)Section 143(3)Section 250Section 68

accounts as income of the appellant. 2.2 In doing so, he did not consider the fact that the assessee was following percentage completion method and the advances received from the debtors were not income of that year but was to be considered as income only based on percentage completion ... gross receipts. 6. The learned Authorised Representative ('ld. AR' for short) for the assessee contended that the assessee has been following Percentage Completion Method and had filed the relevant details before the ld. CIT(A) which was not considered by him. Further, the ld. AR stated that

Alliance Nirmaan Limited, Bareilly vs. PCIT, Bareilly

In the result, the appeal of the assessee is allowed

ITA 119/LKW/2022[2017-18]Status: DisposedITAT Lucknow12 Jun 2025AY 2017-18

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

Section 143(3)Section 263

Honour on the basis of merit as well. The same is as under: 1. POCM Method justification and working The working for the Percentage Completion method was provided during assessment on 23.11.2019 in a detailed reply in which the method was explained in Point No. 5. An additional note

I.P. Constructions Pvt Ltd, New Delhi vs. ITO -12(4), New Delhi

In the result, the appeal of appellant/assessee is allowed for statistical purposes

ITA 5531/DEL/2024[2015-16]Status: DisposedITAT Delhi11 Jun 2025AY 2015-16

Bench: Shri S Rifaur Rahman & Shri Vimal Kumarassessment Year: 2015-16 M/S. I.P. Constructions Private Vs. Acit, Limited, 210 First Floor, Phool Circle-12(2), Singh Market Main, Delhi Vikas Marg, New Delhi Pin 1100 92 Pan No. Aabci4548K (Appellant) (Respondent)

For Appellant: Shri Vishal Chandra Gupta, CAFor Respondent: Shri Om Prakash, Sr. DR
Section 131Section 142(1)Section 143(1)Section 143(2)Section 143(3)Section 250Section 271(1)(b)Section 40A(2)(b)Section 56(2)(viib)

received during the year [verify applicability of Sec.56(2)(viib)]. 2. Real estate business with high closing stock (verify whether assessee has adopted percentage completion method). 3. Mismatch in amount paid to related persons u/s 40A(2)(b) reported in Audit Report and ITR.” 3. Notice under Section

Aravali Buildhomes LLP, Jaipur vs. AO CPC, Jaipur

In the result, the appeal of the assessee is allowed

ITA 1154/JPR/2024[2021-22]Status: DisposedITAT Jaipur04 Jun 2025AY 2021-22

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Sh. Ashok Kumar Gupta, AdvFor Respondent: Sh. Anoop Singh, Addl. CIT
Section 139Section 139(1)Section 139(4)Section 143(1)Section 234ASection 80Section 80ASection 80I

Deduction under section 80IB was not examined and considered on merits by the Assessing Officer. The contention that if the petitioner had followed percentage completion method claim for issue of deduction under section 80IB would have arisen in subsequent year was a hypothetical. Petitioner was required and CBDT was justified

Friday Storytellers LLP, Mumbai vs. ITO, Ward, 4(2)(1), Mumbai

In the result, the appeal of the assessee is allowed for

ITA 5546/MUM/2024[2021-22]Status: DisposedITAT Mumbai30 May 2025AY 2021-22

Bench: Shri Om Prakash Kant () & Shri Rahul Chaudhary ()

For Respondent: Mr. Karan Thaker a/w

transfer pricing provisions does not hinge upon the assessee's method of accounting—whether it adopts the project completion method or the percentage completion method. What is relevant is that international transactions occurred in the year under consideration, and once so established, such transactions are subject to benchmarking ... work-in- progress, which would ultimately impact the computation of profits in the year in which the project is completed. Conversely, under the percentage completion method, profits are recognised in proportion to the stage of completion, and adjustments are applied accordingly in each year based on the extent of revenue

Beauty Etoile Private Limited, Mumbai vs. Assessment Unit, Income Tax Department, Delhi

In the result, appeal of the assessee is allowed

ITA 4073/MUM/2024[2020-21]Status: DisposedITAT Mumbai29 May 2025AY 2020-21

Bench: Shri Pawan Singh & Shri Girish Agrawalassessment Year: 2020-21

For Appellant: Shri. Dharan Gandhi, AdvocateFor Respondent: Shri. Kiran Unavekar, Sr. DR
Section 143(3)Section 144Section 144CSection 144C(15)(b)Section 144C(5)Section 234Section 234ASection 270ASection 948

never be disallowed u/s.94B of the Act. Assessee also asserted that part of interest was capitalized in inventory of WIP. Since it followed percentage completion method, such interest expenditure was recognised in the profit and loss account in the subsequent Assessment Year, i.e., 2023-24 and was disallowed u/s.94B ... profit and loss account for the year under consideration. On this aspect, it is also important to note that assessee follows percentage completion method and such interest expenditure is recognised in the profit and loss account in the subsequent Assessment Year, i.e., 2023-24 and is disallowed u/s.94B in that

Ashiana Buildprop Private Limited, Udaipur vs. DCIT, Central Circle-1, Udiapur, Udaipur

ITA 709/JODH/2024[2016-17]Status: DisposedITAT Jodhpur26 May 2025AY 2016-17

Bench: DR. MITHA LAL MEENA (Accountant Member), DR. S. SEETHALAKSHMI (Judicial Member)

Section 132Section 145(3)Section 153ASection 234ASection 250

ignored. 2.3 The ld. CIT(A) stated that the argument of the appellant is that unbilled sale is the difference because of following percentage completion method as per accounting standard. If this is true, then the appellant should have shown that the total amount of sale ... over the years from the project and because of following the Ashiana Buildprop Pvt. Ltd., Udaipur. percentage completion method there are differences in the figures of sale booked in different years. However, it is evident that the appellant has not made any effort in this regard. In the absence