Retention money received, after TDS, but subject to bank
guarantee, is not chargeable to tax as income till all conditions are
satisfied
Mere receipt of income is not the sole test of chargeability. Receipt
of income refers to the first occasion when the recipient gets the
money under his own control. The words “accrue” or “arises” do
not mean
actual receipt of profits or gains. Both these words are used in
contradistinction to the word “receive” and include a right to receive.
Thus, if an assessee acquires a right to receive the income, the income
can be said to accrue to him though it may be received later on