Form 26AS receipts cannot be taxed twice if earlier-year offering is supported; incomplete reconciliation justified remand for fresh verification.

Form 26AS receipts appearing in a later year cannot be taxed again if the assessee can show, through proper reconciliation of bills, books and third-party evidence, that the same income was already offered in an earlier year. The timing mismatch between accrual-based accounting and later tax deduction required factual verification, and the assessee had not been given adequate opportunity to place reconciliation material before the lower authorities. The matter was therefore remanded for de novo examination by the Assessing Officer with reasonable opportunity to the assessee, leaving the disputed addition open for fresh consideration.

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Issues: Whether the addition made on the basis of Form 26AS receipts reflected in the current year, despite the assessee's claim that the corresponding income had already been offered in the immediately preceding year, was sustainable or required fresh verification.

Analysis: The dispute turned on whether there was a timing mismatch between accrual-based recognition by the assessee and the deduction of tax by the payers in the later year. Since the same receipts cannot be brought to tax twice, the claim that the income was already offered in the earlier year required factual verification through reconciliation of bills, books of account, and third-party evidence. The assessee had not been given adequate opportunity to place the reconciliation material before the lower authorities, and the fresh material was not examined in the proper perspective. The record therefore called for a de novo inquiry into whether the impugned receipts had already suffered tax in the earlier assessment year.

Conclusion: The matter was not finally decided on merits of the addition and was restored to the Assessing Officer for fresh verification with reasonable opportunity to the assessee.

Final Conclusion: The appeal succeeded only to the extent of remand, and the disputed addition was left open for reconsideration after fresh factual examination.

Ratio Decidendi: An amount reflected in Form 26AS cannot be taxed again in a later year if the assessee demonstrates, on proper reconciliation and evidence, that the same income was already offered to tax in an earlier year; where such verification is incomplete, remand for fresh examination is appropriate.

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