Assessee raised demand upon State Electricity Boards of several other States towards transmission charges (wheeling charges) for transmission of exchange of electricity by assessee amongst these States, however due to dispute with regard to such wheeling charges amongst all these states and there was an uncertainty of receiving same did not recognise the revenue said wheeling charges as income. The AO made an addition on account of such wheeling charges. Tribunal deleted the addition. Dismissing the appeal of the revenue the Court held that since there was an uncertainty of receiving wheeling charges due to dispute and income did not accrue to assessee during year, same could not be subjected to tax. Order of Tribunal is affirmed. (AY. 2001-02)