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TMI Blog2019 (1) TMI 1342X X X X Extracts X X X X X X X X Extracts X X X X ..... ount which have been matured along with interest had been offered to tax during different period for the assessment years 2012-13 and 2011-12. Though this aspect was pointed out to the Tribunal by way of the Miscellaneous Petition, the Tribunal pointed out that this mistake pointed out by the assessee is not apparent on the record to revise the order of the Tribunal by following the decision of this Court in the case of Express Newspapers Ltd. Vs. DCIT [2009 (11) TMI 15 - MADRAS HIGH COURT]. The above reconciliation given by the assessee, in our considered view, needs to be looked into because the matured amount along with interest has been offered to tax during the relevant assessment year. Thus for the above reason we are inclined to r ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... revenue for tax purpose. 5. It is further stated by the assesse that the term deposit envisaged the right to receive interest on the principal amount only at the time of maturity/expiry of the term and the concept of reckoning income both in cash system of accounting and accrual system of accounting should be noted as different from the liability to deduct tax at source. 6. It is the case of the assessee that the liability to deduct tax at source should be created statutorily at the time of making the payment of interest or crediting the account of the recipient including the suspense account as per Section 194A of the Act and accordingly, the banker deducted the tax at source in the assessee's case and duly reflected in form No.2 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... rm deposit, the right to receive the interest would get postponed to the date of maturity and in such circumstances, the reckoning of income both under cash system of accounting and accrual system of accounting should ordinarily get postponed to the date of maturity. 10. Therefore, the assessee contended that as per the terms and conditions of the term deposit, the right to receive the interest and the principal would get crystallized at the end of the term of the respective deposits and the assessee has offered the interest income of the respective deposits on the maturity/end of the term of such deposits which happened to be the subsequent assessment year. Before us, the assessee has placed reconciliation statement which is as follows: ..... X X X X Extracts X X X X X X X X Extracts X X X X
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