https://www.taxtmi.com/caselaws?id=28615 Income is treated as arising only when the assessee acquires an enforceable right to receive it, and supervening exchange restrictions that frustrate payment in the agreed contractual mode can defer taxability; on that principle, interest on the foreign debentures was not regarded as accruing in the earlier year. For interest paid to a foreign parent on promissory notes, the sterling note interest was treated as allowable expenditure with no obligation to deduct tax at source where section 42 did not apply, while the rupee note interest was disallowable in the non-resident year but allowable when the assessee was assessed as resident. en-us Wed, 18 Mar 1970 00:00:00 +0530 Wed, 24 Feb 2010 11:24:24 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=28615 Income is treated as arising only when the assessee acquires an enforceable right to receive it, and supervening exchange restrictions that frustrate payment in the agreed contractual mode can defer taxability; on that principle, interest on the foreign debentures was not regarded as accruing in the earlier year. For interest paid to a foreign parent on promissory notes, the sterling note interest was treated as allowable expenditure with no obligation to deduct tax at source where section 42 did not apply, while the rupee note interest was disallowable in the non-resident year but allowable when the assessee was assessed as resident. Case-Laws Income Tax Wed, 18 Mar 1970 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=28615