Allowing the appeal of the assessee the Tribunal held that the concept of accrual of income needs to be considered in the light of the real income theory. Where accrual of income takes place but its realisation becomes impossible, such hypothetical income cannot be charged to tax. Addition made in respect of interest on deposit with the Rupee Co-Operative Bank Ltd was deleted. (dt. 11-5-2021) (AY. 2013-14).
Nutan Warehousing Co. Pvt. Ltd. v. ACIT (2021) BCAJ-July-P. 46 (Pune)(Trib.)
S. 145 : Method of accounting-Accrual of income-Real income theory-Interest income-Realisation becomes impossible-Income cannot be assessed on hypothetical basis. [S. 4, 5]