Reversal of opening accrued and unbilled revenue already...

Reversal of opening accrued and unbilled revenue already recognised and taxed in an earlier year was allowable where an indistinguishable coordinate-bench ruling applied; the related disallowance was deleted. Professional fees paid to non-residents were not established as royalty under the applicable tax treaty. Consequently, non-deduction of tax under section 195 did not justify disallowance, and deletion of that adjustment was sustained. The taxpayer's appeal succeeded, while the Revenue's appeal failed.