Double taxation barred where the same undisclosed income was already offered and taxed in a later assessment year.

Adding the same undisclosed income again in Assessment Year 2006-07 would amount to double taxation where that very amount had already been disclosed, accepted, and taxed in Assessment Year 2007-08 at the same rate. The rule that income must be taxed in the year of accrual was held inapplicable on these facts because the matter involved a one-time disclosure, not shifting of profits through an accounting method. The Tribunal's finding that the disclosure was made at the behest of revenue authorities was not challenged. The addition for Assessment Year 2006-07 was therefore rightly deleted, and no substantial question of law arose.

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Issues: Whether the addition of undisclosed income in Assessment Year 2006-07, when the same amount had already been offered to tax and accepted in Assessment Year 2007-08, would amount to double taxation and give rise to any substantial question of law.

Analysis: The tax authorities had accepted the assessee's disclosure of the undisclosed income in Assessment Year 2007-08 and tax had been paid on that amount. The impugned addition for Assessment Year 2006-07 represented part of the same amount already brought to tax in the later year. As the tax rate in both years was the same, adding the same amount again would result in taxing the same income twice. The reliance on the rule that income must be taxed in the year of accrual was found inapplicable on the facts because the matter involved a one-time declaration of income and not a case of profit shifting through an accounting method. The finding of the Tribunal that the disclosure was made at the behest of the revenue authorities was also not assailed.

Conclusion: The addition for Assessment Year 2006-07 was rightly deleted, and no substantial question of law arose.

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