High Court held that it is only such an income which dissipates midway and will never reach assessee that can be characterized as not income accruing or arising to an assessee and not because, even though assessee gets a right to claim that amount, in reality it does not reach assessee for any reason. Further, where interest accrued to assessee-company with lapse of time on basis of agreement between assessee and its business associates, particularly agreement indicating that assessee would be entitled to claim 21 per cent interest per annum, income automatically accrued to it with lapse of time and there was no question of amount being whisked away as not being income by calling in aid theory of no real income, etc. Order of High Court affirmed. (AY. 1996-97 & 1997-98)