The dispute concerned whether retention money withheld by principal contractors formed taxable income of the assessee in the relevant assessment year. Ltd., the CIT(A) held that retention money did not accrue as income in the year of billing. However, the CIT(A) directed that while retention money was to be excluded from taxable income for AY 2014–15, the corresponding TDS claimed on such retention money could not be allowed in that year and would be allowable only in the year in which the retention money was offered to tax. The Tribunal observed that the right to receive retention money was contingent upon satisfactory completion of contractual obligations and certification, and thus represented deferred payment. The Tribunal confirmed that retention money becomes taxable only in the year when contractual conditions are fulfilled and the right to receive crystallises.