Dismissing the appeal of the revenue , the Court held that ;there was no right to receive income of Rs .1.98 crores as interest as the development agreement has not been executed , therefore the interest has not accrued , income cannot be assessed on hypothetical basis .Further Board of directors of the assessee company had on 23 rd May 2007 passed a resolution , waiving the interest receivable. ( AY.2008-09)