disallowance of ₹72,67,00,000/- by the learned CIT (A) as made by the ld. AO on account of delayed payment surcharge by the consumers. 4.1. The learned AO during the assessment proceeding noted from the documents/evidences furnished by assessee that assessee had followed mercantile/ accrual system of accounting and with regard to delayed payment of surcharge (DPS) assessee