Delhi Tribunal  held that where royalty receivable from sub-licensee was not recognised in the relevant year because there was no reasonable certainty of collection, and the amount ultimately remained unrealised and was later written off, such royalty could not be taxed merely because the payer had deducted tax at source and reflected it in Form 26AS. Applying the real income theory and AS-9 on revenue recognition, the Tribunal held that income which did not materialise and whose collectability was uncertain could not be brought to tax on hypothetical accrual. The fact that the assessee subsequently recognised the income in the next year, raised invoice, created provision and ultimately wrote off the receivable showed at best a timing difference, and TDS deduction by payer did not ipso facto crystallise income in the assessee’s hands. Accordingly, the addition of Rs. 79,81,999 made as undisclosed professional income was deleted. However, since the assessee had claimed TDS credit of Rs. 7,98,200, the Tribunal held that by virtue of section 198, tax deducted at source is deemed income received for computing total income and there is no prescribed mechanism to simply withdraw the TDS claim; hence only Rs. 7,98,200 was to be taxed, granting net relief of Rs. 71,83,799. Appeal partly allowed. (ITA No. 4713/Del/2019 dt. 6-6-2025).  (A.Y 2012-13).