Where an assessee claims that receipts appearing in Form 26AS...

Where an assessee claims that receipts appearing in Form 26AS relate to an earlier year under accrual-based recognition, the crucial question is whether the same income was already taxed in that year, because double taxation of the same receipt is impermissible. The Tribunal found that the reconciliation between bills raised in the preceding year and current-year Form 26AS entries required factual verification. As adequate opportunity had not been given before the AO, and the appellate authority had not properly examined the earlier-year material, the matter was remitted for de novo verification. The assessee was to be given a reasonable opportunity to substantiate the reconciliation with supporting third-party evidence.