Assessee  is engaged in business of providing telecom services to both prepaid and postpaid subscribers. AO held that assessee must account for and include entire amount paid on date of purchase of prepaid card by subscriber. Tribunal accepted assessee’s plea that unutilized amount on prepaid card at end of year was to be treated as advance in balance-sheet and recognized as a revenue receipt in subsequent year, when talk time was actually used or was exhausted. High Court affirmed the order of Tribunal. (AY. 2003-04, 2004-05, 2009-10)