Retention Money taxable when right to receive accrues not on mere billing

Brief Facts of the Case and Question

Brief Facts: The assesse has filed its return of income electronically declaring total income of Rs. 41, 60,580/. Then the case of the assessee was selected for scrutiny assessment and a notice u/s. 143(2) was issued and served upon the assessee by the Assessing officer. Assessee has claimed retention money of Rs. 7 lacs which has been excluded from the profits.

On appeal, Ld. Commissioner of Income

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