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8.Before us,the AR argued that the assessee was engaged in the business of interior decoration, that it would undertake and execute comprehensive works contracts on turnkey basis for interior decoration premises according to the drawings and specifications of customers,that on getting contracts and advances the assessee would commence purchase of specific materials and engage requisite labour force on a sub contractual basis wherever necessary,that all such sub-contractors were directly responsible to the assessee,that Running Bills(RB) submitted by the assessee would be certified by the Architects/Interior Designers/PMC appointed by the customers after examining the work done upto the date of RB as to the measurement, quality, quantity, etc.,that based on such certification payments would be released to the extent of the amount certified,that observation of the AO that the search team found two set of RB of same number, same date but of different amount" was factually incorrect,that the AO had failed to appreciate the fact that one set of RB were seized during the search proceedings and other set of bills were produced by the person searched during the course of assessment proceedings,that the AO had failed to appreciate the fact that the assessee had not issued two different sets of RB containing the same number and same date,that Suresh Nanda had also admitted during the assessment proceedings that the RB seized during the search were the bills pertaining to the work carried out at the Sonali Farm,that second set of RB produced by Suresh Nanda were not made available to the assessee and the same was also not available with the AO,that alleged second set could not be treated as evidence,that the AO had failed to appreciate the fact that the amounts mentioned in RB seized from the premises of the customer (subject to certification of the Architect)and that the amount of RB as per records of the assessee were the same,that due to dispute in quantity, quality and rate charged by the assessee the RB raised by the assessee were passed for ad-hoc payments,that the AO only referred to the bill amount and the amount approved for payment,that he had not noted the important and material remark by the project architect that "approval for ad-hoc payment" on the face of RA bill 1,2 and 4,that the assessee had also objected the same by writing letters to Nanda and the Architect, that to resolve the dispute a Third party Auditor was appointed by Nanda,that extract of the Audit findings provided to the assessee by the Customer was placed before the AO,that on getting Auditor's Report detailed discussions and negotiations for pending items were held with the customer,that to avoid further disputes and delay the assessee raised final bill in respect of work completed on 20.04.2007,that the AO had ignored the above referred evidences filed by the assessee during the assessment proceedings,that without appreciating the practice followed in the industry the AO concluded that the difference in RB amount and amount certified by the customer on ad hoc basis was received by the assessee in cash,that conclusion drawn by the AO was without any corroborative evidence of receipt of cash,that the assessee had regularly followed the practice of submitting RB and Final Bill to all Customers,that it would submit fair and final bill approval of the architect specially when the when contracts were executed over longer period of time.He further argued that Fund Flow Statement was unsigned loose paper and hence could not be considered as evidence,that Suresh Nanda had also denied the correctness about the referred Fund Flow Statement,that he had confirmed,in his replies against query by his AO,that the contract value mentioned in the Fund Flow Statement was wrongly stated,that the correct contract value was Rs.5.09 Crores,that the AO had failed to appreciate the fact that the Fund Flow Statement was one of the estimate made by the person searched,that he ignored the covering note which clearly stated that the figures 5 3580 JKF appearing in the statement were budgeted figures on the day of preparing the statement,that in the column titled as Contractor / consultant at Sr. No. 13,15 and 16 and 18 of the statement "YTB decided" had been typed which meant that the relevant contractors of consultants were yet to be decided on the date of preparation the estimate,that the AO failed to understand the concept of the RB which included certified or uncertified amount of previous RB plus value of additional work carried out after raising previous RB,that the last RB was the correct indicator of the total work done by the assessee,that he added cumulative amount of all RB instead of considering cumulative value of last RB while arriving at total contract value, that the AO had erred in making addition amounting to Rs. 2,48,03,984/- towards unaccounted cash receipts without any corroborative evidence.He further argued that after detailed discussions in respect of audit findings and negotiations for pending items with the customer,it had raised final bill in respect of work completed in AY. 2008-09 and accounted accordingly during relevant AY.2008- 09,that against the bill so raised for Rs.2,47,84,631.98, the amount of Rs.1,24, 20, 071/- was received by the assessee till 31.03.2007,that balance amount of Rs.1,23, 64,560/ -was received by the assessee on 14.06.2011 i.e.during AY.2012-13,that considering the issues involved in dispute raised by the customer and uncertainty about the certified value of the Bill the assessee had shown Rs.1 ,24,20,000/ -till 31.03.2007 as Work in Progress. The AR referred to provisions of Accounting Standard(AS) -29 and contended that the assessee could not recognize the amount of income as it was uncertain in A.Y.2007-08,that it had recorded the said amount in A.Y.2008- 09 after detailed discussions and finalising the same,that as per AS-1 the revenue receivable could not be recorded in books for the year under appeal as it was uncertain, that it was only after third party independent audit and detailed discussions that the revenue became certain,that the assessee assessee had rightly offered it in AY.2008-09. He referred to the page no.28,39 to 69,70-72,78-82 of the Paper book(PB).