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E. D. Sassoon And Company Ltd vs The Commissioner Of Income-Tax,Bombay ... on 14 May, 1954

"8. We have considered the rival submissions of the Ld. Representatives of the parties and have also gone through the record. We find force in the contention raised by the Ld. Counsel for the assessee. Admittedly, a sum of Rs. 18,00,000/- was deposited in the Escrow Account. Both the transferor and transferee had common rights over the said amount as the said amount was deposited in the Escrow Account as a security in respect of future liabilities of the company/transferor. There was no certainty about the quantum of amount likely to be received by transferor or transferee out of the said amount deposited in Escrow Account. Even there was no certainty of the time of release of the said amount or the part of the amount to either of the parties as a dispute between the parties had occurred and litigation was going on. In these circumstances, it cannot be said that the assessee had got a vested right to receive the amount in question. It was only at the end of the litigation that the rights and liabilities of the transferor and transferee were ascertained and thereupon the share of the assessee was passed on to the assessee for which the assessee offered capital gains in the immediate A. Y. 2010-11. The Hon'ble Bombay High Court in the case of CIT Vs. Hemel Raju Shete' (supra) while relying upon the decision of the Hon'ble Supreme Court in 'E.D. Sassoon & Co. Ltd. Vs. CIT (supra) has observed that when the taxpayer did not have the vested right to receive a particular amount, it cannot be said that the said amount has accrued to the taxpayer.
Supreme Court of India Cites 31 - Cited by 1764 - N H Bhagwati - Full Document

Pr. Commissioner Of Income Tax-1, ... vs Sh. Mahipinder Singh Sandhu on 12 March, 2019

6. The ld. Counsel for the assessee took us through Slump Sale Agreement, whose copy is available at page No. 1 to174 of the Paper Book. He has pointed out that under clause 4.8, the conditions for Escrow Account are being provided in this Agreement and if these conditions are perused, then it would reveal that the amount to the extent of Rs.2,60,25,000/- was not accrued or crystallized in favour of vendor. It was contingent one and subject to fulfillment of conditions mentioned in para 4.8.1 to 4.8.3. Thus, the Revenue failed to appreciate the concept of maintaining Escrow Account and also lost sight that tax rate is similar in both the assessment years upon the assessee. The assessee has already offered this amount for taxation in assessment year 2013-14 which has been accepted by the Revenue. For buttressing his contentions, he relied upon the judgement of Hon'ble Punjab & Haryana High Court in the case of Pr. Commissioner of Income Tax, Chandigarh Vs Shri Mahipinder Singh Sandhu reported in 2019 (3) TMI ITA No.997/CHD/2024 & SA/24/CHD/2024 A.Y.2012-13 5 1358. He has placed on record copy of this judgement. According to the ld. Counsel for the assessee, Hon'ble Court has explained the concept of Escrow Account and as to how the amount kept in Escrow Account is to be treated as contingent one.
Punjab-Haryana High Court Cites 8 - Cited by 1 - A K Mittal - Full Document

Assistant Commissioner Of Income-Tax, ... vs Smt. Nilavati Neminath Shete,, ... on 26 April, 2021

"8. We have considered the rival submissions of the Ld. Representatives of the parties and have also gone through the record. We find force in the contention raised by the Ld. Counsel for the assessee. Admittedly, a sum of Rs. 18,00,000/- was deposited in the Escrow Account. Both the transferor and transferee had common rights over the said amount as the said amount was deposited in the Escrow Account as a security in respect of future liabilities of the company/transferor. There was no certainty about the quantum of amount likely to be received by transferor or transferee out of the said amount deposited in Escrow Account. Even there was no certainty of the time of release of the said amount or the part of the amount to either of the parties as a dispute between the parties had occurred and litigation was going on. In these circumstances, it cannot be said that the assessee had got a vested right to receive the amount in question. It was only at the end of the litigation that the rights and liabilities of the transferor and transferee were ascertained and thereupon the share of the assessee was passed on to the assessee for which the assessee offered capital gains in the immediate A. Y. 2010-11. The Hon'ble Bombay High Court in the case of CIT Vs. Hemel Raju Shete' (supra) while relying upon the decision of the Hon'ble Supreme Court in 'E.D. Sassoon & Co. Ltd. Vs. CIT (supra) has observed that when the taxpayer did not have the vested right to receive a particular amount, it cannot be said that the said amount has accrued to the taxpayer.
Income Tax Appellate Tribunal - Pune Cites 1 - Cited by 0 - Full Document
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