Assessee-company, engaged in time-share business, collected membership fee upfront for 33 years and credited portion to Deferred Income account, recognising 40 per cent as income in initial years and 60 per cent in later years, deferring balance over contract period. Assessing Officer disallowed the deferral, citing the mercantile system and lack of provision to defer revenue, and noted separate collection of annual maintenance and utility charges.  Tribunal deleted the addition. On appeal, the Court held that time-share membership fee received upfront could be deferred and recognised as income over the tenure of membership contract, applying the matching principle, notwithstanding mercantile system and absence of express statutory provision to defer revenue, and despite separate collection of annual maintenance and utility charges. (AY. 1998-99 to 2002-03)