the issue is covered by the decision of the Apex Court in the case ofCITv.Shoorji Vallabdas & Co.[1962] 46 ITR 144wherein it is held that "Income tax is a levy on income. No doubt, the Income-tax Act takes into account two points of time at which the liability to tax is attracted, viz., the accrual of the income or its receipt; but the substance of the matter is the income, if income does not result at all, there cannot be a tax " So also inMorvi Industries Ltd.(supra), the Supreme Court has held that income accrues when there is a corresponding liability on the other party. In the present facts, in terms of the MOU, there is no liability on the other party to pay the amounts.