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ITAT permitted non-corporate assessee's change from mercantile to cash accounting system for interest income recognition. The change was deemed legitimate due to borrowers' financial distress and assessee's consistent application in subsequent years. ITAT rejected Revenue's contention to tax unpaid interest income from SPCPL and Roxanna on accrual basis. While SPCPL had not accrued the waived interest in its books, Roxanna, despite accruing the expense, had not paid the interest. CIT(A)'s deletion of AO's addition towards interest income was upheld, acknowledging assessee's right to adopt either accounting method and commitment to declare income upon actual receipt. Revenue's grounds were dismissed.
ITAT permitted non-corporate assessee's change from mercantile to cash accounting system for interest income recognition. The change was deemed legitimate due to borrowers' financial distress and assessee's consistent application in subsequent years. ITAT rejected Revenue's contention to tax unpaid interest income from SPCPL and Roxanna on accrual basis. While SPCPL had not accrued the waived interest in its books, Roxanna, despite accruing the expense, had not paid the interest. CIT(A)'s deletion of AO's addition towards interest income was upheld, acknowledging assessee's right to adopt either accounting method and commitment to declare income upon actual receipt. Revenue's grounds were dismissed.
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