https://www.taxtmi.com/caselaws?id=20973 HC held that the additional amount claimed by the non-resident petroleum distributor under the COPE Scheme did not accrue as income in AY 1975-76. Although the assessee followed the mercantile system, there was no crystallized legal right to receive the amount, as the claim was contrary to the Ministry of Petroleum's directive and had neither been accepted by the Government nor adjudicated or settled. Mere raising of a claim or accounting entry could not constitute accrual of income. The disputed sum was thus not taxable in AY 1975-76. HC noted that the assessee accepted its taxability in AY 1978-79, where the assessment had attained finality. en-us Wed, 21 Nov 1990 00:00:00 +0530 Wed, 10 Dec 2025 15:08:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=20973 HC held that the additional amount claimed by the non-resident petroleum distributor under the COPE Scheme did not accrue as income in AY 1975-76. Although the assessee followed the mercantile system, there was no crystallized legal right to receive the amount, as the claim was contrary to the Ministry of Petroleum's directive and had neither been accepted by the Government nor adjudicated or settled. Mere raising of a claim or accounting entry could not constitute accrual of income. The disputed sum was thus not taxable in AY 1975-76. HC noted that the assessee accepted its taxability in AY 1978-79, where the assessment had attained finality. Case-Laws Income Tax Wed, 21 Nov 1990 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=20973