RBI Norms cannot override Income Tax Provisions

It is a fact that assessee has not booked the lease rentals as noted by the AO but on the reason that the assessee being NBFC is following the guidelines issued by RBI and guidelines states that once the party has become a defaulter for at least twelve months that party can be declared as NPA and no income on that part can be booked from the source after failure to get any income.In the present case all parties have become NPAs and, therefore, the assessee has not booked the lease rentals due from them. As argued by Ld. CIT, DR that this issue is squarely covered by the decision of ITAT, Delhi...