Revenue cannot withhold Tax refund for Tax on revenue neutral transaction

Ericsson India Private Limited Vs ACIT (Delhi High Court)

It is not as if the petitioner/assessee is not offering unearned revenue for tax; it is only on account of accounting policy followed consistently that unearned revenue is offered for tax in the year in which services are rendered and/or goods are sold. Thus, the transaction, in effect, being revenue neutral, it does not affect the interest of revenue.

The upshot of the aforesaid discussion is that the estimation made by the AO that

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