Accrual of interest income failed where waiver was accepted and no liability was acknowledged, leaving no substantial question of law.

Interest income was held not to have accrued where the investee companies requested waiver and the assessee accepted that request, leaving no acknowledged interest liability. On that factual foundation, the Tribunal concluded that the claimed return depended on future contingencies and was therefore not taxable as accrued income under the Indo-Cyprus DTAA. Because the issue turned on these factual findings, the Court found no substantial question of law and declined to interfere, including on the asserted transfer pricing objection.

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Issues: Whether the appeal raised any substantial question of law on the taxability of interest income under the Indo-Cyprus DTAA in light of the factual finding that interest had been waived and was not accruing.

Analysis: The Tribunal's finding was that the investee companies had requested waiver of interest and the assessee had acceded to that request. On that factual foundation, the interest could not be said to have accrued, as the investee companies had not acknowledged any interest liability and the claimed return was dependent on future contingencies. In view of this factual conclusion, the Court found no basis to interfere on the issue of taxability or to examine the asserted transfer pricing objection.

Conclusion: No substantial question of law arose for consideration, and the appeal failed.

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