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TMI Blog2002 (2) TMI 78X X X X Extracts X X X X X X X X Extracts X X X X ..... R LAL GUPTA J.-The Tribunal has referred the following question for the opinion of this court in respect of the assessment years 1988-89 and 1991-92: "Whether, on the facts and in the circumstances of the case, the Income-tax Appellate Tribunal was right in law in allowing change in system of accounting of interest income only from mercantile to hybrid system of accounting, whereby interest incom ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... income by way of interest, but since the amount has not been recovered, it was not credited to the interest account. In respect of the assessment year 1991-92, the amount was Rs.6,39,727. The Assessing Officer did not accept the assessee's claim regarding change in the method of accounting and made the additions of the aforesaid amounts to the income of the assessee in respect of the two assessme ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... interest. So far as the receipts are concerned, the assessee had adopted the cash system. Resultantly, the interest which had accrued but was not recovered from the loanees was not added to the income by the assessee. The assessee had explained that it was being burdened with liability to pay tax even though "it was not realising interest in time" from the loanees. Faced with the situation, the as ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the period under consideration. However, the provision cannot be interpreted to mean that once a system of accounting is adopted, it can never be changed. "Regular" cannot in the present context cannot mean permanent. It has not been pointed out with reference to any provision that a change is impermissible or barred even when it is warranted by the existing situation. We cannot also lose sight ..... X X X X Extracts X X X X X X X X Extracts X X X X
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