In the result, appeal of the assessee is allowed for statistical purpose
Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh
capital gains which have not accrued or arisen to him. It would indeed be most harsh and inequitable to tax the assessee on income which has neither arisen to him nor is received by him, merely because he has carried out the contractual obligation undertaken by him. It is difficult to conceive of any rational reason why the Legislature should