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TMI Blog1986 (1) TMI 152X X X X Extracts X X X X X X X X Extracts X X X X ..... rtained offered the same for taxation. The assessment year involved in 1981-82 and whatever interest was assignable for this year was offered for taxation by the assessee and subjected to tax. 3. The CIT in the light of certain case laws came to the conclusion that entire interest was to be included in the hands of the assessee in the year when it was received and it could not be allowed to be ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... d counsel for the assessee also came forward with a battery of decisions in support of assessee's contention viz. Joya Narayan Panigrahi vs. CIT (1974) 93 ITR 102 (Ori), CIT vs. Sampangirmaiah, V. (1968) 69 ITR 159 (Mys), CIT vs. Shamlal Narula (Dr.) (1972) 84 ITR 625 (P H), Om Prakash vs. CIT (1984) 42 CTR (Del) 175 : (1984) 148 ITR 150 (Del), CIT vs. Deokinandan Sons (1982) 138 ITR 225 (Del), ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... r of the CIT. Though we may also observe before we part as pointed out by the ld. counsel for the assessee that the payment was not received during the year under consideration because the assessment year involved is 1981-82 for which the relevant previous year ended on 31st March, 1981 whereas neither the date of order falls during accounting period relevant nor the payment. This all becomes acad ..... X X X X Extracts X X X X X X X X Extracts X X X X
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