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25. On a consideration of the facts, we see no reason to sustain the addition. The decisions in Y.N.S. Hobbs' case (supra) and Shaw Wallace & Co. Ltd.'s case (supra) directly support the assessee's case. What is taxable in the hands of the assessee is what accrues to it by way of income. In a case where amounts are deducted from a gross figure and only the net amount is available to the assesses, apart from any reliance on a real income theory, even, as a matter of fact, the assessee cannot claim that he has or is entitled to receive the withheld tax. The position, perhaps, would have been different if that amount of tax is entitled to being accounted for as tax paid by the assessee in India. In no income or tax computation in India will the assessee get any deduction or credit for this sum of 50,000 Dollars. It is clearly in the nature of an outgoing from a gross amount the assessee is entitled to receive. Both from the theoretical and from the practical point of view, a compulsorily withheld tax outside India cannot be different in concept from a compulsory expenditure or other outgoing. Only the net constitutes the assessee's income accrued or receivable. On this ground alone the addition should be deleted.