The assessee accounted for and offered the surcharge income on receipt basis. The AO sought to tax the same on accrual basis, irrespective of collection. Dismissing the appeal of the revenue the Court held that,  that where the assessee, owing to uncertainty in collection, offered the surcharge income on receipt basis and the same was accepted in the earlier years, the addition made in the instant  assessment year  was also to be deleted and the income is to be taxed on receipt basis. (AY. 2005-06)