Race-winning income accrues in the earlier accounting year and is not assessable in the later assessment year.

Jackpot or race-winning income was treated as having accrued and been received before 1 April 1972, placing it in the accounting period 1971-72 relevant to assessment year 1972-73. Because the case involved no factual distinction from an earlier decision on identical facts, the same reasoning was applied. The reference was answered in the affirmative and against the Revenue, so the income was not assessable for assessment year 1973-74.

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Issues: Whether the jackpot/race-winning income accrued in the financial year ending 31 March 1972 so as to be assessable for assessment year 1972-73, and not for assessment year 1973-74.

Analysis: The earlier decision on identical facts had held that the race-winning income accrued and was received before 1 April 1972, falling in the accounting period 1971-72 relevant to assessment year 1972-73. As the present case involved no factual distinction from that decision, the same reasoning governed the reference.

Conclusion: The question was answered in the affirmative and against the Revenue, confirming that the income was not assessable for assessment year 1973-74.

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