https://www.taxtmi.com/caselaws?id=797766 Reversal of opening accrued or unbilled revenue is allowable where revenue was consistently recognised on the mercantile basis according to work performed, offered to tax on accrual, and retained as an asset until billing. Amounts reversed on subsequent billing, including earlier-year billing adjustments, do not create fresh taxable income where they were already recognised and taxed. Professional fees paid to non-resident member firms do not attract withholding-based disallowance where the payments are not consideration for protected rights, know-how, or information constituting royalty under the applicable tax treaties, and the recipients have no permanent establishment in India. Consequently, disallowance for non-deduction of tax is not sustainable. en-us Wed, 12 Aug 2026 00:00:00 +0530 Thu, 27 Aug 2026 08:28:55 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=797766 Reversal of opening accrued or unbilled revenue is allowable where revenue was consistently recognised on the mercantile basis according to work performed, offered to tax on accrual, and retained as an asset until billing. Amounts reversed on subsequent billing, including earlier-year billing adjustments, do not create fresh taxable income where they were already recognised and taxed. Professional fees paid to non-resident member firms do not attract withholding-based disallowance where the payments are not consideration for protected rights, know-how, or information constituting royalty under the applicable tax treaties, and the recipients have no permanent establishment in India. Consequently, disallowance for non-deduction of tax is not sustainable. Case-Laws Income Tax Wed, 12 Aug 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=797766