Dismissing the appeal of the assessee the Court held that, gain arising on account of securitization of lease receivables and credited to the Profit & Loss Account is a taxable receipt in the year of securitisation. Followed  CIT v.T. V. Sunderam Iyengar (1996)  222 ITR 344 (SC). Argument that the entry represents hypothetical income and not real income and that the amount is assessable in subsequent years on receivable basis is not correct. Question of whether income can also be deferred to subsequent years under the “Matching concept” as per Taparia Tools Ltd v. JCIT (2003) 260 ITR 102 (Bom)/ Taparia Tools Ltd v. JCIT  ( 2015)  372 ITR 605 (SC) left open. ( AY. 2002-03, 2003 -04)( ITA No. 256 of 2016, dt. 17.09.2018)

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