( 1 ) HEARD learned counsel for the parties. These two income-tax appeals under Section 260a of the Income-tax Act, 1961, are being disposed of by a common judgment. The questions of law involved in these two appeals are as follows :

" (i) Whether, in the facts and circumstances of the case, the receivable amount of interest which has been credited by the assessee-appellant to the account, named as deferred credit interest on overdue interest bills account and debited to the account named as deferred credit interest receivable account was merely hypothetical income and not real income of the assessee-appellant and was taxable under the Income-tax Act, 1961 ? (ii) Whether, the Income-tax Appellate Tribunal erred in law in appreciating and applying the correct concept of real income (either actually received or accrued), as laid down by the Supreme court in various cases to find out the taxability of the aforesaid amount under the Income-tax act, 1961 ?"

( 2 ) THESE two appeals relate to the assessment years 1990-91 and 1991-92. The facts of the case as alleged by the assessee are as follows : the assessee is a company and is a wholly owned Central Government undertaking. It has been

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