Dismissing the appeal of the Revenue the Court held that from a reading of the order two findings of fact emerged. First, the money received by the assessee was offered to tax only when services were rendered. Second, this was an accounting practice followed consistently for several years. Lastly, since the tax rate remained the same, no loss was caused to the Revenue by the assessee offering the amount for the tax in the subsequent period. Order of Tribunal is affirmed. Followed CIT v. Nagri Mills Co Ltd (1958) 33 ITR 681 (Bom)(HC), CIT v. Dinesh Kumar Goel (2011) 331 ITR 10 (Delhi)(HC) (AY.2010-11)