https://www.taxtmi.com/caselaws?id=221674 Interest earned on fixed deposits created from withdrawn against a bank guarantee, while the underlying arbitral challenge remained pending, was not treated as accrued real income. The court reasoned that entitlement to retain both the principal and the interest was contingent on the final outcome of the challenge, and the prospect of restitution under Section 144 CPC confirmed that the receipt was provisional rather than final. As no crystallised income arose, refusal of a certificate under Section 197 of the Income-tax Act was unjustified, and the taxpayer was entitled to the certificate for the relevant year. en-us Thu, 21 Feb 2013 00:00:00 +0530 Wed, 23 Oct 2013 16:31:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=221674 Interest earned on fixed deposits created from withdrawn against a bank guarantee, while the underlying arbitral challenge remained pending, was not treated as accrued real income. The court reasoned that entitlement to retain both the principal and the interest was contingent on the final outcome of the challenge, and the prospect of restitution under Section 144 CPC confirmed that the receipt was provisional rather than final. As no crystallised income arose, refusal of a certificate under Section 197 of the Income-tax Act was unjustified, and the taxpayer was entitled to the certificate for the relevant year. Case-Laws Income Tax Thu, 21 Feb 2013 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=221674