“11. In this case the liability to pay interest would arise when the compensation amount due to the assessee had not been paid, in each of the relevant years. Therefore, the accrual of interest has to be spread over the years between the date of acquisition till it was actually paid. We are not in a position to accept the contention of the revenue that even if the accrual has taken place earlier, the Income-tax Officer can proceed to assess the income on the basis of receipt notwithstanding the earlier accrual as he has an option to assess the income by way of interest either on the basis of accrual or on the basis of receipt, and that the decision of the Mysore High Court in Commissioner of Income-tax v. Sampangiramaiah, in so far as it proceeds that the accrual alone should be taken as the basis for assessment, cannot be taken as laying down the correct law. The statute, in our view, does not give such an option to the revenue, as is contended, to choose either the accrual basis or the receipt basis for assessing the income. When a statute brings to charge certain income, its intention is to enforce the charge at the earliest point of time. If the income has accrued earlier and the assessee treats it as taxable during the year of accrual, it is not open to the revenue to treat it as an income in the year of receipt in a case where the assessee follows the mercantile basis of accounts, If such an option is given, the same income becomes taxable twice, once on the basis of accrual and another on the basis of receipt. The Supreme Court has pointed o u t i n Laxmipat Singhania Vs. Commissioner of Income-tax, that:
