TMI Blog2024 (7) TMI 785X X X X Extracts X X X X X X X X Extracts X X X X ..... iled by the assessee were heard together and are being disposed off, by this consolidated order. 2. The brief facts of the case are that the assessee has filed his return of income for the A.Y 2021-22 on 28.10.2022 and for the A.Y 2022-23 on 5.3.2022. The appellant company follows the percentage completion method and recognizes revenue in the books of account in accordance with applicable accounting standard/ICDS. The assessee entered into long term contract with NCC-Matrix Consortium and the works started in the financial year relevant to A.Y 2018-19 and continued upto A.Y 2023-24. Accordingly, the assessee recognizes the income in terms of percentage completion method of contract and claimed TDS to the extent the income was recognized in ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the assessee and upheld the assessment order passed by the Assessing Officer u/s 143(1) of the I.T. Act, 1961. 3. Aggrieved by such order of the learned CIT (A,) the assessee is in appeal before the Tribunal. 4. The learned Counsel for the assessee submitted that the reasons for mismatch of TDS between Form 26AS of the relevant A.Y and return of income is mainly due to the method of accounting followed by the assessee, as per which the appellant is following percentage completion method for recognizing the revenue which des not match exactly with the payment made or credited by the contractors. The learned Counsel for the assessee submitted that the appellant has carried out long-term contract awarded by the NCC-Matrix Consortium which r ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... red to tax on percentage completion method irrespective of the invoice raised/amount accrued upon in the contract. The assessee executed the contract awarded by NCC Matrix Consortium which started from financial year 2017-18 and continued upto financial year 2022-23. The appellant claims that in case of percentage completion method revenue recognition, it may not match with contract receipts and relevant TDS credited as per Form 26AS. We find merit in the submission of the assessee for the simple reason that when the appellant is following percentage completion method for recognition of the Revenue, it may not match with the income from operations or receipts from its business and corresponding TDS credit as per Form 26AS. This is for the s ..... X X X X Extracts X X X X X X X X Extracts X X X X
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