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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, 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)

taxmann.com 35 (Calcutta); “Where assessee was engaged in business of construction and development of property and it had been following project completion method which had 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

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)

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 it is almost complete, however subsequently it was stated that only ... method of accounting as compared to the previous year. Whereas in reply dated 05.03.2021 assessee has submitted that it has followed project completion method in AY 2016-17. The submission of the assessee has been reproduced as under for ready reference: " With reference to the difference in the revenue recognition

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)

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 it is almost complete, however subsequently it was stated that only ... method of accounting as compared to the previous year. Whereas in reply dated 05.03.2021 assessee has submitted that it has followed project completion method in AY 2016-17. The submission of the assessee has been reproduced as under for ready reference: " With reference to the difference in the revenue recognition

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

also not applicable to the assessee under consideration, as the assessee is in real estate development. Moreover, assessee is following the project completion method. Therefore, Ld. Counsel submitted that Ld.CIT(A) has passed the reasoned and speaking order and therefore the order of Ld.CIT(A) may be upheld. 15. About

Virendra Prakash Sharma, Jaipur vs. DCIT Circle (Intl Tax), Jaipur

In the result, the appeal of the assessee is allowed

ITA 286/JPR/2025[2020-21]Status: DisposedITAT Jaipur16 Jul 2025AY 2020-21
For Appellant: Shri Rajeev Sogani, CA &For Respondent: Smt. Runi Pal, CIT (Th. VC)
Section 132Section 143(3)Section 144C(13)Section 144C(5)Section 153CSection 69

hands only. Further, the AO has erroneously split the on-money payment as unaccounted income for different years on basis of 'project completion method". This basis of bifurcation is not very significant as AO did not have corresponding evidence that the concerned Builder was indeed collecting on money from building

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

amount to Rs.2,32,46,520/- and added back with the total income of the assessee. The assessee is recognised its revenue under project-completion method. During 4 ITA 5456,5469 & 5470//Mum /2024 Kavya KCD Developers the impugned assessment year, the assessee had not booked any revenue ... allowed. Being aggrieved, both assesse and revenue filed appeal before us. 4. The Ld.AR, in argument stated that the assessee is continuing with project completion method and still, the assessee is incurring loss on the project as the assessee has not been able to sell the project. The Ld.AR submitted

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

amount to Rs.2,32,46,520/- and added back with the total income of the assessee. The assessee is recognised its revenue under project-completion method. During 4 ITA 5456,5469 & 5470//Mum /2024 Kavya KCD Developers the impugned assessment year, the assessee had not booked any revenue ... allowed. Being aggrieved, both assesse and revenue filed appeal before us. 4. The Ld.AR, in argument stated that the assessee is continuing with project completion method and still, the assessee is incurring loss on the project as the assessee has not been able to sell the project. The Ld.AR submitted

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)

Annexure -VII. A.Y. 2018-19. 8 5.1 Thus, Ld. Counsel submitted that for the first two Assessment Years, the revenue has accepted the Project Completion Method accounting adopted by the assessee and passed regular assessment orders. However, for the present A.Y. 2018-19 the Ld. Assessing Officer in the faceless ... assessment proceedings applied Percentage Completion Method as specified in AS-7 and demanded tax thereon. However, the assessee offered Project Completion Method and offered to tax a sum of Rs. 37,63,23,000/- relating to sale of 121 flats

Samir Narain Bhojwani, Mumbai vs. DCIT 4(2)(1), Mumbai

Appeal of the assessee is allowed for statistical purposes and the appeal of the revenue is dismissed

ITA 261/MUM/2025[2022-23]Status: DisposedITAT Mumbai26 Jun 2025AY 2022-23

Bench: Shri Anikesh Banerjee, Jm & Ms Padmavathy S, Am

For Appellant: Shri Yogesh Thar & Chaitanya
Section 112Section 194CSection 250Section 37(1)Section 40Section 50

IN THE INCOME TAX APPELLATE TRIBUNAL “G” BENCH, MUMBAI BEFORE SHRI ANIKESH BANERJEE, JM & MS PADMAVATHY S, AM I.T.A. No

ACIT 421 Mumbai, Mumbai City vs. Samir Narain Bhojwani, Mumbai

Appeal of the assessee is allowed for statistical purposes and the

ITA 1022/MUM/2025[2022-23]Status: DisposedITAT Mumbai26 Jun 2025AY 2022-23

Bench: Shri Anikesh Banerjee, Jm & Ms Padmavathy S, Am

Section 112Section 194CSection 250Section 37(1)Section 40Section 50

IN THE INCOME TAX APPELLATE TRIBUNAL “G” BENCH, MUMBAI BEFORE SHRI ANIKESH BANERJEE, JM & MS PADMAVATHY S, AM I.T.A. No

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

India which provides for accounting of construction contracts by two methods for the purpose of accounting which is Percentage Completion Method and Project Completion Method, where the assessee is said to be following the Percentage Completion Method, as per which the revenue is recognized to the extent of the completion

DCIT 4(3)(1), Mumbai vs. Manbhari Constructions Private Limited, Mumbai

In the result, the appeal filed by the revenue bearing ITA

ITA 4034/MUM/2024[2016-17]Status: DisposedITAT Mumbai13 Jun 2025AY 2016-17

Bench: Shri Vikram Singh Yadav & Shri Anikesh Banerjee

Section 142(1)Section 143(1)Section 143(2)Section 143(3)Section 194CSection 250

year on account of the sale of Flats made from Prabhadevi Project and the construction of Flats was not completed. That time the project completion method was in raise but later on Percentage of completion of project was introduced and the same is in force. Moreover in this case there

Morparia and Ranka Construction Co., Mumbai vs. ITO 17(2)(3), Mumbai

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

ITA 2786/MUM/2024[2014-2015]Status: DisposedITAT Mumbai28 May 2025AY 2014-2015

Bench: Shri Saktijit Dey & Shri Girish Agrawalassessment Year: 2014-15 Morparia & Ranka Ito 17(2)(3), Mumbai Construction Co. Aaykar Bhavan, Mumbai Office No.307, 3Rd Floor, 400023 Gundecha Chamber, Nagindas Vs. Master Road, Fort, Mumbai 400023 Pan: Aabfm0391D (Appellant) (Respondent) Present For: Assessee : Shri. Vimal Punmiya, Ca Revenue : Shri. Bhangepatil Pushkaraj Ramesh, Sr. Dr Date Of Hearing : 25.04.2025 Date Of Pronouncement : 28.05.2025 O R D E R Per Girish Agrawal: This Appeal Filed By The Assessee Is Against The Order Of National Faceless Appeal Centre (Nfac), Delhi, Vide Appeal No. Cit(A), Mumbai- 28/10833/2016-17 Dated 15.04.2024 Passed Against The Assessment Order By Income Tax Officer 17(2)(3), Mumbai U/S. 143(3) Of The Income- Tax Act, 1961 (Hereinafter Referred To As The “Act”), Dated 28.12.2016 For Assessment Year 2014-15. 2. Grounds Taken By The Assessee Are Reproduced As Under: “1. On The Facts & In The Circumstances Of The Case & In Law The Learned Commissioner Of Income Tax (Appeals) Erred In Confirming Addition Made Of Rs.56500000/- Under Section 28(Iv) Of The Act Which Represents Amount Received & Now Repayable To M/S Crb Capital Market Ltd On Account Of 2

For Appellant: Shri. Vimal Punmiya, CAFor Respondent: Shri. Bhangepatil Pushkaraj
Section 143Section 143(3)Section 234BSection 28

outstanding. The details of the flats sold and amount received is tabulated as under: 4. Assessee claims that it follows project completion method and therefore in year 2006, when the project was completed it recorded sales in its profit and loss account which included sale consideration with the agreement value ... assessee offered the amount of Rs.5.10 Crs as income for the said project in the Asst. Year 2006-2007 since it is following project completion method. The amount as declared by the assessee firm includes Units sold to CRB Capital Market Ltd. and unsold stock of the units

Income Tax Officer, Pune vs. Purple Developers, Pune

In the result, appeal of the revenue is dismissed and that of the assessee is allowed

ITA 2210/MUM/2024[2006-07]Status: DisposedITAT Mumbai27 May 2025AY 2006-07

Bench: Beena Pillai & Shri Girish Agrawalassessment Year: 2006-07

For Appellant: Shri. Rakesh Joshi, CAFor Respondent: Shri. Soumendu Kumar Dash, Sr. DR
Section 143(3)Section 40

account of income on the advances received for row houses by laying undue emphasis on the assessee's claim as regards following the project completion method and in completely ignoring the fact that out of the alleged advances in as much as in five cases, the entire sale consideration ... maintained its books of accounts and all the sales are duly accounted and reported, the method followed by the assessee is of project completion method. In the business in which assessee is engaged, there cannot be a uniformity of selling price, which depends upon several direct and indirect factors, some

Purple Developers, Pune vs. Addl CIT 15(1), Mumbai

In the result, appeal of the revenue is dismissed and that of the assessee is allowed

ITA 5627/MUM/2010[2006-07]Status: DisposedITAT Mumbai27 May 2025AY 2006-07

Bench: Beena Pillai & Shri Girish Agrawalassessment Year: 2006-07

For Appellant: Shri. Rakesh Joshi, CAFor Respondent: Shri. Soumendu Kumar Dash, Sr. DR
Section 143(3)Section 40

account of income on the advances received for row houses by laying undue emphasis on the assessee's claim as regards following the project completion method and in completely ignoring the fact that out of the alleged advances in as much as in five cases, the entire sale consideration ... maintained its books of accounts and all the sales are duly accounted and reported, the method followed by the assessee is of project completion method. In the business in which assessee is engaged, there cannot be a uniformity of selling price, which depends upon several direct and indirect factors, some

Padmanabh Pioneer Promoters LLP, Mumbai vs. Income Tax Officer 25 3 1 Mumbai, Mumbai

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

ITA 5848/MUM/2024[2018-19]Status: DisposedITAT Mumbai21 May 2025AY 2018-19

Bench: Shri Narender Kumar Choudhry & Smt. Renu Jauhriआयकर अपील सं./Ita No. 5848/Mum/2024 (निर्धारण वर्ा / Assessment Year :2018-19) Padmanabh Pioneer V/S. Ito – 25(3)(1), Mumbai Promoters Llp बिधम Kautilya Bhavan, C-41 To C- 4 Buona Casa, Sir P.M. 43, G Block, Bandra Kurla Road, Fort Mumbai- Complex, Bandra (E), 400001 Mumbai-400051 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aanfp9898G Appellant/अपीलधर्थी .. Respondent/प्रनिवधदी

For Appellant: Shri Mihir NaniwadekarFor Respondent: Shri V. K. Chaturvedi
Section 250Section 40

account of under valuation of closing stock, without correctly appreciating the method of accounting regularly followed by the assesse/Appellant i.c. Project Completion Method of Accounting. Hence, the impugned order dated 19.09.2024 passed by Ld. CIT(A) is therefore bad in law and liable to be set aside ... development of a real estate project, ‘Kapil Akhila’, at Pune. The project was started on 05.09.2012, and the assessee has followed the project completion method to book its revenue. During the year under consideration, three flats were sold to different parties and the assessee recognised revenue to the tune

Shri Balbir Singh Verma, Shimla vs. Pr.CIT, Shimla

In the result, appeal of the Assessee is allowed

ITA 314/CHANDI/2020[2015-16]Status: DisposedITAT Chandigarh14 May 2025AY 2015-16

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Parikshit Aggarwal, C.AFor Respondent: Shri Rohit Sharma, CIT DR (Virtual)
Section 133ASection 142(1)Section 143(2)Section 143(3)Section 24Section 263Section 271(1)(c)Section 36(1)(iii)

preceding year. The Ld. AO was also in the knowledge that assessee is selling plots/ flats, collecting advances, maintaining books on project completion method, his WIP of real estate project as at close of the year was in excess of these advances

Pramukh Aranya Developers, Junagadh vs. Pr. CIT, Rajkot-1, Rajkot

In the result, the appeal of the assessee (in ITA No

ITA 372/RJT/2024[2018-19]Status: DisposedITAT Rajkot28 Apr 2025AY 2018-19

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita No.372 /Rjt/2024 (निर्धारण वर्ष/Assessment Year: (2018-19) M/S. Pramukh Aranya Developers Office No. 5, First Floor, Cit Centre, Opp. New Collector Officer, B/H. Sardar Baug, Junagadh - 362001 The Pr. Cit-1, Vs. Aayakar Bhawan, Race Course Ring Road, Rajkot - 360001 स्थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaofp3393F (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) निर्धारिती की ओर से/Appellant By राजस्व की प्रत्यर्थी ओर से/Respondent By : Shri Mehul Ranpura, Ld. Ar : Shri Sanjay Punglia, Ld.Cit (Dr) सुनवाई की तारीख / Date Of Hearing घोषणा की तारीख/Date Of Pronouncement Per Dr. A. L. Saini, Am: : 04/02/2025 : 28/04/2025 आदेश / Order By Way Of This Appeal, The Assessee Has Challenged The Correctness Of The Order Dated 30.03.2024, Passed By The Learned Principal Commissioner Of Income- Tax (In Short “Ld Pcit"), Under Section 263 Of The Income-Tax Act, 1961 (Hereinafter Referred To As 'The Act'), For The Assessment Year2018-19.Grievances Raised By The Assessee, Which, Being Interconnected, Will Be Taken Up Together, Are As Follows: M/S. Pramukh Aranya Developers V. Pcit

For Respondent: Shri Mehul Ranpura, Ld. AR
Section 143(3)Section 22Section 23(5)Section 263

given to their parties/relatives, and the said facts have been examined by the assessing officer, besides, the assessee is following the project completion method to recognise the revenue, therefore, in these circumstances, the assessing officer took the plausible view, which is not erroneous at any rate and therefore the jurisdiction

ACIT, Circle-50(1), New Delhi vs. Harkanwarpal Singh Lamba, New Delhi

In the result, the appeal of the Revenue is allowed for statistical

ITA 604/DEL/2020[2016-17]Status: DisposedITAT Delhi09 Apr 2025AY 2016-17

Bench: Shri Yogesh Kumar Us & Shri Avdhesh Kumar Mishra

Section 10(38)

applicable in his case since he is neither a construction company nor under any construction contract. Thus, the project completion method can be said to be applicable in the case of the appellant which is rightly being followed. It is again specified that the appellant is following this method ... accounting followed by the appellant was duly accepted vide a speaking order for that year. 6.4 It is observed that appellant is following project completion method and offer the income at the time of when the property is actually sold/registered. The appellant has shown the cost of construction incurred

Kashyap Constructions & Developers, Patna vs. ACIT, Cir-4, Patna

In the result, the appeal of the assessee is allowed

ITA 716/PAT/2024[2015-16]Status: DisposedITAT Patna02 Apr 2025AY 2015-16

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm

For Appellant: Shri S .K . Tulsiyan, ARFor Respondent: Shri Rinku Singh, DR
Section 142(1)Section 144Section 144BSection 147Section 148Section 151A

Rupsapur-1 in the town and Disrict of Patna, bearing Survey Plot No.217/, Khata No.04, Thana-22, Danapur, Patna. The assessee was following Project Completion Method (PCM) for the purpose of ascertaining its income. Though the assessee has filed its returns of income