Assessee-company was engaged in business of manufacturing and marketing pharmaceutical products.  During previous year, it sold its marketing division to another company through Business Purchase Agreement (BPA) by way of slump sale. Under Business Purchase Agreement, gross consideration was agreed at Rs. 567.07 crores, out of which Rs. 477.62 crores accrued and became payable upon transfer and balance of Rs. 89.44 crores was placed in Escrow Account and would accrue to assessee annually in five equal instalments of Rs. 17.89 crores each. In the return of income  the  assessee offered a lump-sum payment of Rs. 477.30 crores as well as Rs. 17.89 crores which accrued to assessee during previous year and balance (71.56 crores) was offered in four subsequent assessment years. Assessing Officer treated business purchase agreement and Escrow Agreement independent to each other and held that Escrow Account could not be linked to agreement and, therefore, entire consideration had accrued to assessee in assessment year itself and he brought amount, kept in Escrow Account to tax as income of assessee for assessment year under consideration. On appeal the tribunal held that Escrow account was executed in furtherance of BPA and amount in Escrow Account would accrue to assessee only on fulfilment of certain condition and deposit in Escrow Account was intrinsic and integral to transfer of marketing division under business purchase agreement and without it, sale would be incomplete. Accordingly income which did not accrue to assessee was not liable to tax during the year.  (AY. 2012-13)