Home Case Index All Cases Income Tax Income Tax + AT Income Tax - 2022 (5) TMI AT This
Forgot password New User/ Regiser ⇒ Register to get Live Demo
2022 (5) TMI 41 - AT - Income TaxRevision u/s 263 by CIT - AO has not made proper enquiry in regard to the difference in the receipts as reflected in the 26AS statement and the profit and loss account - HELD THAT:- The orders of the co-ordinate Bench for AY 2008-09, 2011-12 and 2012-13, wherein revenue recognition method adopted by the assessee are accepted. Undoubtedly, it is not the case of the Revenue that the amounts received by the assessee as disclosed in form no.26AS has not been offered by assessee as its income in terms of the agreement with the parties or it is in violation of method of accounting followed consistently. We also found that amount of sum received from Goodwork Communication Pvt. Ltd there is no difference between amount received as per from no. 26AS and amount shown as income. With respect to Reliance Big Entertainment Pvt. Ltd. the amount of receipt shown in form no. 26AS is related to agreement for five years. This amount has been offered for taxation by the assessee in five different years. Similarly, amount received from EPIC channel was provided in agreement for three years and same has also been disclosed as income in three different years - assessee has shown party wise, assessment year wise income offered by it. Such working was based on number of days. In view of this, we hold that learned Assessing Officer has made complete inquiry between mismatch of receipt as per 26AS and income recognized in profit and loss account. Further, as assessee has a method of recognizing revenue as per terms of agreement, over a period of time on the basis of program telecast on number of days, which is also approved by ITAT in its own case, consistently followed by assessee, we do not find that following that method makes the order of learned Assessing Officer erroneous. - Decided in favour of assessee.
|