Assessee entered into a development agreement with a developer for construction of commercial complex. As per said agreement, developer paid an interest-free refundable security deposit of Rs. 50 lakhs to assessee. Assessing Officer took a view that since said amount was not shown by assessee in its accounts as a liability, it was to be treated as assessee’s income under head income from other sources. On writ the Court held that since genuinity of said development agreement was not challenged by revenue, it was not apposite on part of revenue to treat aforesaid amount as revenue receipt for relevant year to impose tax. Accordingly the revenue was to be directed to drop proceedings against assessee to collect tax in respect of said amount. (AY. 2019-20)