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TMI Blog2016 (10) TMI 928X X X X Extracts X X X X X X X X Extracts X X X X ..... ls filed under Section 260A of the Income Tax Act, 1961 (the Act), challenge a common order dated 30th August, 2013 passed by the Income Tax Appellate Tribunal (the Tribunal). The common impugned order relates to the Assessment Years 2003-04, 2004-05, 2005-06 and 2006-07. A separate appeal has been filed for each of the Assessment Years. 2. The Revenue urges the following common question of law i ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e even though the Appellant-Assessee was following the mercantile system of accounting and had offered interest income during the earlier Assessment Years. Therefore, the Assessing Officer in the Assessment Order passed in respect of each of the four years made an addition of interest which had accrued to the Appellant-Assessee. 4. Being aggrieved, the Appellant-Assessee challenged the orders of ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... impugned order upheld the finding of the CIT(A) that interest on the loan had accrued and was to be included in the income of the Appellant. In the above view, all four appeals were dismissed by the impugned order of the Tribunal. 6. Mr. Rattesar, learned Counsel appearing for the Appellant submits that the impugned order is not sustainable in law as it proceeds on the basis that as the mercantil ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... there has been an accrual of interest and following the mercantile system of accounting, the same is real income, liable to tax. 8. In the above view, the fact that all the authorities have come to a finding of fact that income has accrued and nothing was provided by the Appellant before the authorities to establish the impossibility of the recovery of interest from the parties to whom loan was a ..... X X X X Extracts X X X X X X X X Extracts X X X X
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