Without change in circumstances Dept cannot take a different view on methodology of cost allocation accepted in earlier years 

Samarath Realities Vs DCIT (ITAT Ahmedabad)

To sum up, the main arguments of the assessee are that the land cost varies from block to block and therefore the same is variable. The cost of land gets allocated through registered sale deed and the same is transferred to the land owner. The assessee of the project has been consistently following this methodology of cost allocation where through registered deed the consideration of cost of flat is determined and later transferred to the land owner. Therefore, the ld. counsel for

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