How PT TTSI Proven Unbilled Revenue Accuracy Through Accounting Standards.

Tax Dispute of PT TTSI: Validity of Turnover Correction vs. Revenue Recognition of DMS Project Based on PSAK No. 23

The conflict began when the Respondent made a positive correction to the Turnover of Rp997,200,000, claiming the Taxpayer failed to provide competent supporting documents during the audit process. The Respondent relied on Article 26A paragraph (4) of the KUP Law to disqualify evidence newly presented at the appeal stage. However, PT TTSI (formerly PT TTNI) provided a strong argument that this income originated from the Dealer Management Systems (DMS) project, which was only 6% complete by the end of 2017. Based on PSAK No. 23, this income must be recognized even if the invoice has not yet been issued.

Legal Considerations of the Board: Evidentiary Review of Temporary Acceptance Form and Consistent Accounting Principles

The Board of Judges conducted a thorough evidentiary review and found that PT TTSI had consistently applied Indonesian accounting principles. Evidence such as the Temporary Acceptance Form and project progress reports proved that the revenue recognition was legitimate and had been reported in the Corporate Income Tax Return. The Board opined that the Respondent lacked a solid basis to maintain the correction when the Taxpayer had reported income according to the actual situation.

Resolution and Ruling Implications: Complete Cancellation and Synchronization Between Commercial Bookkeeping and Fiscal Reporting

The dispute was resolved by canceling the Respondent's entire correction, reaffirming the importance of synchronization between commercial bookkeeping and fiscal reporting. The implication of this decision provides legal certainty for Taxpayers in consistently applying revenue recognition methods in accordance with accounting standards.

A Comprehensive Analysis and the Tax Court Decision on This Dispute Are Available Here