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Assessee has raised the ground that the Commissioner of Income-tax (Appeals) failed to appreciate that as per the joint development agreement with M/s. Dugar Housing Ltd. the assessee had recognised income as per the percentage of completion basis and offered the same for taxation and hence con firming the addition on me stated pretext that the appellant being a land owner and did not undertake any construction contract was unjustified on the facts of thecase.

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Income Tax Act, 1961—Business Income— Entries in the books of account clearly goes to show that the assessee is only a partner in the development of scheduled property of the agreement and in any event, no addition can be made based on a mere difference between form 26AS and the amount shown in the profit and loss account and in the absence of any reconciliation and corroborative evidence, therefore, it is not the case of the Revenue that there is leakage of revenue during the period of joint development, it is a case of tax neutral, thus, no addition is warranted and the Assessing Officer is directed to delete the addition. - SREE SANKESWARA FOUNDATIONS & INVESTMENTS V/s ASSTT. CIT - [2020] 82 ITR (TRIB) 513 (ITAT-CHENNAI)