On appeal the Tribunal held  that the income earlier disclosed had not materialised because the agreements were terminable or could have been cancelled, that once they were cancelled, the properties reverted back to the assessee, that they were duly reflected in the balance-sheet and as assets of the assessee, that the revised accounts were also scrutinised and found to be in order and meeting the accounting practice adopted. It therefore accepted the return and reversed the order of the Assessing Officer. The High Court dismissed the Department’s appeal holding that no substantial question of law arose, that the findings of the Tribunal were On appeal to the Supreme Court order of High Court affirmed. (AY. 2007-08)