Taxability of interest on disputed enhanced compensation fails until the compensation right finally crystallises.

Interest on enhanced compensation for acquired land was treated as non-taxable where the right to receive the additional compensation remained under challenge in pending appeals and had not crystallised. The court distinguished cases where only quantification of an admitted entitlement remains, holding that a disputed right to receive payment does not give rise to accrued income for the relevant year. It further noted that the issue was already covered by binding Supreme Court precedent on disputed compensation, so the later accrual ruling on enhanced compensation did not apply. The applications for reference therefore failed because no referable question of law arose.

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Issues: Whether interest received on additional compensation for acquired land was taxable when the entitlement to enhanced compensation was still sub judice and whether any referable question of law arose.

Analysis: The additional compensation awarded by the district judge was under challenge in pending appeals, so the right to receive the enhanced amount had not become final. In such a situation, the interest linked to that disputed compensation did not represent an accrued or crystallised income for the relevant year. The distinction drawn in the authorities was between a disputed right to receive payment and a case where only quantification remained to be done; the present matter fell in the former category. The question was already concluded by the earlier Supreme Court ruling governing disputed compensation, and the later decision concerning year-to-year accrual of interest on enhanced compensation did not govern this fact situation.

Conclusion: The interest on additional compensation was not taxable while the compensation dispute remained pending, and no referable question of law arose.

Final Conclusion: The applications seeking a reference failed because the controversy stood covered by binding precedent and the Tribunal's view required no further reference.

Ratio Decidendi: Where the right to receive enhanced compensation is itself in dispute and has not crystallised, interest attached to that disputed amount does not accrue as taxable income until the dispute is finally settled.

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