ORDER A.K. MATHUR, C.J. This is a reference under s. 256(1) of the IT Act. In pursuance of the order passed by this Court on 14th Sept., 1994 in MCC No. 636185 whereby a reference has been called by the High Court at the instance of the assessee and the following question of law has been referred by the Tribunal for opinion of this Court : "Whether, on the facts and in the circumstances of the case, the Tribunal was right in holding that the difference of interest at 2 per cent for various years accrued in the accounting year relevant to the asst. yr. 1973-74 ? 2. The brief facts which are necessary for disposal of this reference, are that the assessee is a private limited company under the liquidation and represented by an Advocate Receiver. Two official liquidators were appointed in 1941. The first Receiver appointed was C.P. Syndicate Ltd., and subsequently this receiver was replaced by another Receiver with the directions that the former Receiver should hand over possession to the latter. It is alleged that at that stage, the former Receiver raised an objection that possession could not be directed to be surrendered as long as the money invested by the Receiver was not refunded. The District Court went into all aspects of the question and held that the subsequent Receiver was to pay the former Receiver a sum of Rs. 97,818. 19 after adjusting all the claims. The District Court directed this amount to be paid by the former Receiver to the latter Receiver with interest at the rate of 3 per cent per annum from 21st Feb;, 1945, till the date of the order, namely 21st Feb., 1963. In appeal to the High Court, the amount was reduced to Rs. 82,891.74 but the rate of interest was enhanced to 5 per cent, by judgment of this Court dt. 5th Sept., 1972, i.e., in the asst. yr. 1973-74. The ITO took the view in subsequent proceedings that the amount of interest representing the difference of 2 per cent (5 per cent minus 3 per cent) should be deemed to have been accrued in the accounting year relevant to the asst. yr. 1973-74, overruling the contention of the assessee that the amount should be spread over in the respective years. This view was confirmed by the first Appellate Authority and the Tribunal in second appeal. yr. 1973-74, overruling the contention of the assessee that the amount should be spread over in the respective years. This view was confirmed by the first Appellate Authority and the Tribunal in second appeal. Hence, the assessee approached the Tribunal for referring the aforesaid question before this Court and accordingly, the aforesaid question of law has been referred by the Tribunal for opinion of this Court. 3. We have heard thelearned counsel for the Revenue and perused the records. We are of the opinion that the view taken by the Tribunal appears to be justified and there is no reason to take a different view from the view taken by the Tribunal. Hence, the aforesaid question is answered in favour of the Revenue and against the assessee.