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“project completion method”

ICDS & AccountingICDS IIIICDS III326 judgments

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

Leading authorities on project 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. Shivalik Buildwell P Ltd.
40 Taxmann.com 219 · 2013 · High Court
44
citing judgments

Real estate developers' profits arise only upon the transfer of title, and advances received from customers cannot be treated as trading receipts in the year of receipt.

CIT v. Ashaland Corporation
133 ITR 55 · 1982 · High Court
44
citing judgments

Income from the sale of immovable property, including any 'on-money' component, is taxable only when the sale is complete, marked by the execution and registration of the sale deed and/or transfer of possession to the buyer.

CIT v. Happy Home Corporation
94 Taxmann.com 292 · 2018 · High Court
42
citing judgments

When a partner admits to undisclosed income during a survey, and that income is linked to future sale deed registrations, it can be considered as income received for the purpose of assessment under Section 145 of the Income-tax Act, 1961, even if it is subject to conditions.

Ltd. v. ITO
64 DTR 251 · 2011 · ITAT
39
citing judgments

The Assessing Officer accepted the assessee's claim of being in the construction business and its use of the project completion method, and the Revenue did not take remedial measures under sections 263 or 147, indicating acceptance of the assessment.

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.

Judgments citing project completion method

ACIT, Chennai vs. M/S. Bsr Builders Engineers Contractors, Chennai

In the result, the appeal of the assessee for AYs 2016-17 & 2017-18

ITA 1561/CHNY/2025[2016]Status: DisposedITAT Chennai14 Jan 2026

Bench: Shri Aby T. Varkey & Shri Jagadishआयकर अपील सं./Ita Nos.1311 & 1312/Chny/2025 िनधा"रणवष"/Assessment Years: 2016-17 & 2017-18 V. Bsr Builders Engineers Contractors, The Dcit, No.28, Bsr Janus, Tank Bund Road, Central Circle-2(3), Nungambakkam, Chennai-600 034. Chennai. [Pan: Aagfb 7140 N] (अपीलाथ"/Appellant) (""यथ"/Respondent) आयकर अपील सं./Ita Nos.1274 & 1561/Chny/2025 िनधा"रणवष"/Assessment Years: 2017-18 & 2016-17 V. The Dcit / Acit, Bsr Builders Engineers Central Circle-2(3), Contractors, Chennai. No.28, Bsr Janus, Tank Bund Road, Nungambakkam, Chennai-600 034. [Pan: Aagfb 7140 N] (अपीलाथ"/Appellant) (""यथ"/Respondent)

For Appellant: Mr.G. Baskar, Advocate &For Respondent: Mr.Nishanth Rao, JCIT

same was required to be offered to tax, in the year in which the project was completed, as the assessee was following ‘Project Completion Method’. The Ld. AR has further brought to our notice that, the project in question, was completed in AY 2019-20 and that the assessee ... examination of the submission of the appellant it can be seen that the appellant firm submits that it has been consistently following the “Project Completion Method” of accounting. Since the OMR Road Project was not completed during the AY 2016-17, the receipts for the sale of space

Bsr Builders Engineers Contractors, Chennai vs. DCIT, Central Circle-2(3), Chennai

In the result, the appeal of the assessee for AYs 2016-17 & 2017-18

ITA 1312/CHNY/2025[2017-18]Status: DisposedITAT Chennai14 Jan 2026AY 2017-18

Bench: Shri Aby T. Varkey & Shri Jagadishआयकर अपील सं./Ita Nos.1311 & 1312/Chny/2025 िनधा"रणवष"/Assessment Years: 2016-17 & 2017-18 V. Bsr Builders Engineers Contractors, The Dcit, No.28, Bsr Janus, Tank Bund Road, Central Circle-2(3), Nungambakkam, Chennai-600 034. Chennai. [Pan: Aagfb 7140 N] (अपीलाथ"/Appellant) (""यथ"/Respondent) आयकर अपील सं./Ita Nos.1274 & 1561/Chny/2025 िनधा"रणवष"/Assessment Years: 2017-18 & 2016-17 V. The Dcit / Acit, Bsr Builders Engineers Central Circle-2(3), Contractors, Chennai. No.28, Bsr Janus, Tank Bund Road, Nungambakkam, Chennai-600 034. [Pan: Aagfb 7140 N] (अपीलाथ"/Appellant) (""यथ"/Respondent)

For Appellant: Mr.G. Baskar, Advocate &For Respondent: Mr.Nishanth Rao, JCIT

same was required to be offered to tax, in the year in which the project was completed, as the assessee was following ‘Project Completion Method’. The Ld. AR has further brought to our notice that, the project in question, was completed in AY 2019-20 and that the assessee ... examination of the submission of the appellant it can be seen that the appellant firm submits that it has been consistently following the “Project Completion Method” of accounting. Since the OMR Road Project was not completed during the AY 2016-17, the receipts for the sale of space

Bsr Builders Engineers Contractors, Chennai vs. DCIT, Cent. Circle-2(3), Chennai

In the result, the appeal of the assessee for AYs 2016-17 & 2017-18

ITA 1311/CHNY/2025[2016-17]Status: DisposedITAT Chennai14 Jan 2026AY 2016-17

Bench: Shri Aby T. Varkey & Shri Jagadishआयकर अपील सं./Ita Nos.1311 & 1312/Chny/2025 िनधा"रणवष"/Assessment Years: 2016-17 & 2017-18 V. Bsr Builders Engineers Contractors, The Dcit, No.28, Bsr Janus, Tank Bund Road, Central Circle-2(3), Nungambakkam, Chennai-600 034. Chennai. [Pan: Aagfb 7140 N] (अपीलाथ"/Appellant) (""यथ"/Respondent) आयकर अपील सं./Ita Nos.1274 & 1561/Chny/2025 िनधा"रणवष"/Assessment Years: 2017-18 & 2016-17 V. The Dcit / Acit, Bsr Builders Engineers Central Circle-2(3), Contractors, Chennai. No.28, Bsr Janus, Tank Bund Road, Nungambakkam, Chennai-600 034. [Pan: Aagfb 7140 N] (अपीलाथ"/Appellant) (""यथ"/Respondent)

For Appellant: Mr.G. Baskar, Advocate &For Respondent: Mr.Nishanth Rao, JCIT

same was required to be offered to tax, in the year in which the project was completed, as the assessee was following ‘Project Completion Method’. The Ld. AR has further brought to our notice that, the project in question, was completed in AY 2019-20 and that the assessee ... examination of the submission of the appellant it can be seen that the appellant firm submits that it has been consistently following the “Project Completion Method” of accounting. Since the OMR Road Project was not completed during the AY 2016-17, the receipts for the sale of space

DCIT, Chennai vs. Bsr Builders Engineers Contractors, Chennai

In the result, the appeal of the assessee for AYs 2016-17 & 2017-18

ITA 1274/CHNY/2025[2017]Status: DisposedITAT Chennai14 Jan 2026

Bench: Shri Aby T. Varkey & Shri Jagadishआयकर अपील सं./Ita Nos.1311 & 1312/Chny/2025 िनधा"रणवष"/Assessment Years: 2016-17 & 2017-18 V. Bsr Builders Engineers Contractors, The Dcit, No.28, Bsr Janus, Tank Bund Road, Central Circle-2(3), Nungambakkam, Chennai-600 034. Chennai. [Pan: Aagfb 7140 N] (अपीलाथ"/Appellant) (""यथ"/Respondent) आयकर अपील सं./Ita Nos.1274 & 1561/Chny/2025 िनधा"रणवष"/Assessment Years: 2017-18 & 2016-17 V. The Dcit / Acit, Bsr Builders Engineers Central Circle-2(3), Contractors, Chennai. No.28, Bsr Janus, Tank Bund Road, Nungambakkam, Chennai-600 034. [Pan: Aagfb 7140 N] (अपीलाथ"/Appellant) (""यथ"/Respondent)

For Appellant: Mr.G. Baskar, Advocate &For Respondent: Mr.Nishanth Rao, JCIT

same was required to be offered to tax, in the year in which the project was completed, as the assessee was following ‘Project Completion Method’. The Ld. AR has further brought to our notice that, the project in question, was completed in AY 2019-20 and that the assessee ... examination of the submission of the appellant it can be seen that the appellant firm submits that it has been consistently following the “Project Completion Method” of accounting. Since the OMR Road Project was not completed during the AY 2016-17, the receipts for the sale of space

Sameer Ramesh Vashi, Mumbai vs. The Principal Commissioner of Income Tax, Mumbai-17, Mumbai

In the result, appeal of the assessee is allowed

ITA 164/MUM/2025[2018-2019]Status: DisposedITAT Mumbai30 Oct 2025AY 2018-2019

Bench: Shri Amit Shukla & Shri Girish Agrawalassessment Year: 2018-19 Sameer Ramesh Vashi Vs The Principal Commissioner 702, Samrock Apartment, C.D. Of Income Tax, Barfiwala Road, Andheri-West, Mumbai-17 Mumbai - 400058 [Pan: Aaapv6356Q] Appellant Respondent Present For: Assessee : Dr. K. Shivaram, Sr. Advocate & Shri Rahul Hakani, Advocate Revenue : Shri Satyaprakash R. Singh, Cit Dr Date Of Hearing : 06.08.2025 Date Of Pronouncement : 30.10.2025 O R D E R Per Girish Agrawal: This Appeal Filed By The Assessee Is Against The Revisionary Order Of Pcit, Mumbai–17, Vide Order No. Itba/Com/F/17/2024- 25/1070374871(1), Dated 14.11.2024 Passed U/S. 263 Against The Assessment Order By National E-Assessment Centre, Delhi, U/S.143(3) R.W.S. 143(3A) & 143(3B) Of The Income-Tax Act, 1961 (Hereinafter Referred To As The “Act”), Dated 14.03.2023 For Ay 2018-19. 2. Grounds Taken By The Assessee Are Reproduced As Under: 1. The Pcit, Mumbai-17 Erred In Passing Order U/S 263 & Holding That Order Passed U/S 143(3) Dt 24-03-2021 Is Erroneous & Prejudicial To The Interest Of Revenue & Hence Directed The Ao To Reframe The Assessment.

For Appellant: Dr. K. Shivaram, Sr. Advocate and Shri Rahul Hakani, AdvocateFor Respondent: Shri Satyaprakash R. Singh, CIT DR
Section 142(1)Section 143(2)Section 143(3)Section 263

also submitted that method of recognition of revenue for the real estate projects undertaken by the assessee is by following project completion method which has been accepted by the Department 4 Sameer Ramesh Vashi AY 2018-19 since past several years. Claim of expenditure are in respect of administrative expenses