https://www.taxtmi.com/caselaws?id=432608 Income accrued only when the right to receive arose on rendering the corresponding services, so tuition fee collected in the last quarter for services to be rendered in the next financial year could not be taxed on accrual basis in the same year. Remittances to foreign educational institutions for syllabus, question paper, training and examination-related activities were not fee for technical services, as the payments fell within the educational treaty exclusion and the assessee acted only as a collecting and remitting conduit; the related disallowance was therefore unsustainable. A contingent liability disclosed in the accounts did not establish waiver of interest under section 41(1) without proof of actual waiver or benefit in the relevant year, so that addition also failed. en-us Thu, 26 May 2022 00:00:00 +0530 Mon, 09 Jan 2023 17:50:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=432608 Income accrued only when the right to receive arose on rendering the corresponding services, so tuition fee collected in the last quarter for services to be rendered in the next financial year could not be taxed on accrual basis in the same year. Remittances to foreign educational institutions for syllabus, question paper, training and examination-related activities were not fee for technical services, as the payments fell within the educational treaty exclusion and the assessee acted only as a collecting and remitting conduit; the related disallowance was therefore unsustainable. A contingent liability disclosed in the accounts did not establish waiver of interest under section 41(1) without proof of actual waiver or benefit in the relevant year, so that addition also failed. Case-Laws Income Tax Thu, 26 May 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=432608