The aassessee sold its share holdings in the wholly owned  subsidiary. As per purchase agreement certain amount to be kept in  escrow account as deposits. The amount to be released after 2^nd year,  4^th year  and 8^th year on certain agreed terms after adjusting of claim arising of potential liabilities in a manner prescribed therein.  The AO made addition on the basis of consideration specified in the agreement and has  considered the amount kept in escrow account  also as accrued to the assessee. CIT(A) affirmed the order of the AO. On appeal the Tribunal held that    funds have not been released to the assessee till date, therefore, the amount kept in escrow deposits cannot be regarded as sale consideration accrued to the assessee with reference to S 48 for the purposes of quantification of capital gains chargeable under s. 45. Amount recovered out of escrow account by the assessee in the later years shall be liable to taxation in the respective years of receipt or accrual. Dinesh Vazirani v. P CIT (2022) 445 ITR 110 (Bom) followed; Caborandum Universal Ltd. v. Asstt. CIT (2021) 283 Taxman 312 (Mad) (HC),  distinguished. (AY. 2012-13)