Assessee-contractor was awarded a canal construction contract by KBJNL. Disputes arose leading to arbitration, in which assessee’s claim was allowed. District Court partly confirmed the arbitral award. In KBJNL’s appeal, the Karnataka High Court stayed operation of the District Court’s order and directed KBJNL to deposit ₹3 crores as an interim measure, which KBJNL deposited (excluding TDS) in the assessee’s account during pendency of appeal. Assessing Officer treated ₹3 crores as revenue receipt taxable in the year of receipt. Tribunal affirmed the order of the Assessing Officer. On appeal, the Court held that the amount deposited pursuant to the interim order of the Karnataka High Court could not be treated as revenue receipt taxable in the year of receipt since the assessee’s right to receive had not crystallised and would be taxable only when the dispute was finally resolved in assessee’s favour. (AY. 2006-07)