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INCOME TAX APPELLATE TRIBUNAL (MUMBAI BENCH)
Anikesh Banerjee, Judicial Member, Girish Agrawal, Accountant Member
Assistant Commissioner of Income Tax – Appellant
Versus
Vidhi Enterprises – Respondent
| Table of Content |
|---|
| 1. initiation of reassessment and factual background of redevelopment sale. (Para 2 , 3) |
| 2. parties' arguments on revenue recognition timing and precedents. (Para 4 , 5 , 6 , 7) |
| 3. no income accrual in ay 2018-19; transfer on possession and payment. (Para 8) |
| 4. revenue appeal dismissed, cit(a) upheld. (Para 9) |
ORDER
Per: Anikesh Banerjee (JM):
The instant appeal of the revenue filed against the order of the NFAC, Delhi [for brevity ‘the Ld. CIT(A)’], order passed under section 250 of the Income Tax Act 1961 (for brevity ‘the Act’) for assessment year 2018-19, date of order 04.04.2025. The impugned order emanated from the order of the Ld. Assessment Unit Income Tax Department (for brevity the ‘Ld. AO’), order passed under section 147 r.w.s. 144B of the Act date of order 22.03.2024.
2. The revenue has taken the following grounds:
“1. "Whether on the fact and in the circumstances of the case and in law, the Ld. CIT(A) erred in deleting the addition of Rs. 108134530/-made on account of Profits and gains from Business of the assessee on sale of the property for the relevant Assessment year?"
2. "Whether on the fact and in the circumstances of the case and in law, the Ld. CIT(A)
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