No addition for income offered in subsequent year if tax effect remains same

PCIT Vs Adani Infrastructure and Developers Pvt. Ltd. (Gujarat High Court) Revenue contended that provisional fees was not being treated as income during the year by ignoring the Section 199 of the Act read with Rule 37BA of the Rules. Admittedly there is no provision under the Act to tax the same income twice as done in the instant case. The contention of the assessee that the impugned income has been offered to tax in the subsequent year has not been disregarded by the authorities below. Therefore, we are of the considered view that, if any addition is made in the year under consideration, t...