https://www.taxtmi.com/caselaws?id=117948 The Tribunal concluded that the technical know-how fees received by the non-resident company (Tolerant/Veritas) were not assessable in the relevant year. Income accrued only upon final acceptance of the arbitration award by both parties, postponing accrual until 1990. Disputes between HCL and Tolerant regarding contractual obligations significantly affected the accrual of income. The Tribunal emphasized that income under a contract accrues only upon resolution of disputes. HCL's challenge to the Assessing Officer's jurisdiction for reassessment was dismissed. The appeal was partly allowed, with no costs awarded. en-us Tue, 31 Aug 2004 00:00:00 +0530 Wed, 27 Jun 2012 15:30:24 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=117948 The Tribunal concluded that the technical know-how fees received by the non-resident company (Tolerant/Veritas) were not assessable in the relevant year. Income accrued only upon final acceptance of the arbitration award by both parties, postponing accrual until 1990. Disputes between HCL and Tolerant regarding contractual obligations significantly affected the accrual of income. The Tribunal emphasized that income under a contract accrues only upon resolution of disputes. HCL's challenge to the Assessing Officer's jurisdiction for reassessment was dismissed. The appeal was partly allowed, with no costs awarded. Case-Laws Income Tax Tue, 31 Aug 2004 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=117948