The petitioner received the interest on income tax refunds pertaining to assessment years 2009-10 and 2010 -11 , which was credited in the Financial year  2013 -14 ( AY. 2014-15) . The interest amount was shown as income in the AY. 2014 -15 , the assessment was completed u/s 143(3) of  the  Act . The  assessment for the assessment year 2011-12 was reopened on the grounds that the said interest was  received during the previous year 2011 -12 . The AO added the said amount in the assessment year 2012 -13 , however he has not reduced the said income from the assessment year 2014 -15 . The petitioner  filed an appeal before the CIT(A) for the assessment year 2012 -13 . When the appeal was pending the petitioner applied for the Direct Tax Vivad Se Vishwas Act , 2020 for the settlement of dispute  which was accepted .     The petitioner filed Revision application  for the assessment year 2014 -15 . As the application was not taken up for hearing for more than five years the petitioner filed writ petition before the High Court . High Court directed the Commissioner to dispose the application . The Commissioner rejected the application on merits and the petitioner filed writ petition against the rejection order . Allowing the petition the Court held that  it is settled law that same amount cannot be taxed twice . The Court also held that merely because the assessee has offered a receipt of income in his return of income does not necessarily make him liable to pay tax on the said receipt if otherwise said income is not chargeable to tax  . High Court directed the Commissioner to pass fresh order as per the direction of the High Court . Relied on  CIT v. Shelly Products  (2003) 261 ITR 367 /  129 Taxman 271/  181 CTR 564 (SC)  ( 2003) 6 SCC 461 , Vijay Gupta v .CIT  (2016) 386 ITR 643 / 238 Taxman 505 / 137 DTR 401 (2017) 291 CTR 517 ( Delhi(HC) / (2016) SCC Online  Del  161 .  ( WP  (L) No. 11708 of 2021 & CM APP 36194 of 2021  dt . 20-1-2023 )   (AY . 2014 -15 )