Case of PCIT vs EMC Limited, SC Judgement Dated 8th January 2026. The Assessing Officer had treated retention money of Rs 142.53 crore as income, on the ground that the amount had been credited by the principal contractors and tax was deducted at source under section 194C, which the assessee had also claimed as TDS credit. The assessee contended that under the terms of the contracts, a portion of the consideration was retained and payable only after successful completion of projects and issuance of completion or taking-over certificates. Until fulfilment of these conditions, the assessee had no enforceable right to receive the retention money, and therefore no income accrued in that year. HC had concluded that retention money, being contingent and deferred, could not be treated as income of the assessee in the year in which it was retained. The apex court upheld the HC ruling.