( 1 ) INCOME-TAX Appellate Tribunal has dismissed the appeal filed by the Revenue, inter alia, holding that in the absence of any material change in the facts, the view taken by the authorities for the earlier assessment years would continue to hold good on the principles of consistency. The Revenue has assailed the correctness of that finding in the present appeal.

( 2 ) THE assessee-company was incorporated on 24th February, 1989 with the object of carrying on business in the development of real estate. It appears to have entered into an agreement in February, 1989 with Edward keventer Pvt. Ltd. and taken over the responsibility of re-development of land owned by the said company. It also entered into an agreement with M/s. Ballarpur industries Ltd. in March, 1989 and with M/ s. Ashoka Builders in June 1989. Pursuant to the said agreements the assessee had received a sum of Rs. 5 crores from M/s. Ballapur industries Ltd. and Rs. 2 crores from M/s. Ashoka Builders, subject to certain conditions, stipulated in the agreements.

( 3 ) THE assessee-company, it is common ground, follows the project completion method of accounting, accepted in the course of the preceding