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Whether the tribunal was correct in holding that the travel expenses incurred by employees of the assessee computed based on average basis should be upheld and not on trip vise basis as contemplated under Rule 6D of the I.T. Rules as held by jurisdictional Bombay High Court as the order was passed by the assessing officer in Mumbai?

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Section 5 & 80HHC of the Income-Tax Act, 1961—Income- Tribunal has permitted deduction on accrual basis and has held that an amount would be receivable only when the income accrues to the assessee and income would accrue to the assessee only when the assessee gets such a right to receive the income and it further held that assessee would get a right to receive the amount only when it is sanctioned to the assessee by the custom authorities and not when the assessee makes a claim of the same, since, the amount of cash compensatory assistance and duty drawback during the relevant year was not sanctioned to the assessee therefore, the income has not accrued to the assessee, thus, the tribunal has allowed the deduction on accrual basis only- - CIT V/s ASEA BROWN BOVERI LTD. - [2020] 26 ITCD Online 133 (KARN)