Real income doctrine cannot defeat tax on a voluntarily offered receipt without supporting evidence for the claimed deduction.

A receipt voluntarily offered as income from other sources remained taxable where the assessee had received the amount, had not refunded it, and continued to contest only the balance in civil proceedings. The plea of non-accrual and real income was rejected because the return itself disclosed the receipt, and the doctrine of real income could not displace the statutory charging scheme. The related claim for coordination and settlement expenses also failed because no vouchers or supporting evidence were produced. Authorities concerning capital gains and unmaterialised transactions were held inapplicable on these facts.

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Issues: Whether the amount of Rs. 1,75,00,000 received by the assessee as a consenting party was rightly taxed as income from other sources and whether the corresponding deduction claimed as coordination and settlement expenses was allowable.

Analysis: The assessee had himself disclosed the receipt as income from other sources and had also claimed an equal deduction as expenses. The deduction was disallowed because no supporting evidence or vouchers were produced. The Tribunal found that the assessee had received the amount during the relevant year, had not refunded it, and was still contesting the balance amount in civil proceedings. The plea of non-accrual and real income was rejected because the assessee had already offered the receipt to tax in the return, and the concept of real income could not override the statutory scheme. The reliance placed on decisions concerning capital gains and unmaterialised transactions was held to be inapplicable on the facts.

Conclusion: The addition was upheld and the assessee's claim for deduction failed.

Ratio Decidendi: A receipt voluntarily offered to tax cannot escape taxation on a plea of non-accrual where the corresponding deduction is unsupported by evidence, and the doctrine of real income cannot be used to defeat the statutory charging provisions.

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