The assessee is in the business of promoter and developer  of land. It sold  the land under  a memorandum of understanding (MOU) for a consideration of 120 crores. The assessee offered only Rs 100 crores for tax in the year 2012-13  as the MOU provided that a sum of Rs 20 Crores would be paid by the purchaser on execution of sale deed after getting plan sanctioned and on inclusion of the name of the purchaser in the 7/12 extract .However  the AO taxed entire sum of Rs 120 crores in the assessment year 2012-13 only . On appeal CIT(A) also confirmed the order of the AO . On further appeal the Tribunal deleted the addition  following the ratio in Morvi Industries  Ltd v. CIT (1971) 82 ITR 835 (SC) .   On appeal by the revenue   dismissing the appeal of the  Court held that , the income accrues only when it becomes  due  when the other party accepts the liability to pay.  Followed  CIT v Shoorji Vallabdas & Co (1962) 46 ITR 144 (SC) , the Court also referred CIT v. Nagri Mills Co .Ltd (1958) 33 ITR 681 (Bom) (HC)  wherein the High Court held that when the tax rate is the same the department should not fritter away the energies in fighting matters . ( ITA No 306/Pun/ 2015 dt 9-02 -2017) (AY. 2012 -13) ( ITA No 1345 of 2017 dt 18 -11-2019)