Held that since petitioner followed a consistent accounting policy to show unearned revenue as current liability in its books of account and offered it for tax as and when services were rendered, transaction in effect being revenue neutral would not affect revenue’s interest. Accordingly   withholding of tax without taking into account financial wherewithal of petitioner was not founded on cogent grounds and refund claimed by petitioner was directed  to be released.  (AY.  2018-19)