Notional JDA Income Not Taxable Without Real Accrual: ITAT Pune

Skyline Developers Vs ITO (ITAT Pune) ITAT Pune: Notional Income from Joint Development Agreement Not Taxable in Absence of Real Accrual – 80IB(10) Disallowance Set Aside The Pune Bench of the ITAT partly allowed the appeal of Skyline Developers for AY 2006-07, holding that income merely recorded on a notional basis due to an erroneous accounting entry cannot be brought to tax when no real income had accrued during the year. While the Tribunal upheld the validity of reassessment proceedings under sections 147/148—since the original return was processed under section 143(1) and a wrong clai...