We are concerned in this appeal with question whether sum of Rs. 3,40,000 claimed as deduction by assessee had fallen due in accounting period relevant to assessment year 1980-81 or not. According to assessee, said sum is monetary valuation of risk calculated as interest; while Income-tax Officer calls it interest simpliciter and it is our risk to determine its character. Indeed, at very beginning of our hearing this difference clearly emerged when we formulated claim as interest and learned representative of assessee at once took stand that it was not interest but risk or anticipated loss only calculated as interest. How this problem has arisen we shall presently see. 2. starting point is that assessee is exporter of goods to Sudan. According to assessee, risk regarding obtaining payment for exports to that country is large and it is this particular factor which has occasioned claim of assessee as risk or anticipated loss. assessee has tried to substantiate this by pointing out letter dated 29-8-1979/4-9-1979 from Export Credit & Guarantee Corporation Limited to assessee, wherein under column 'Terms' following is stated: "On terms of payment against documents on arrival of steamer." It shows that payment is not on basis of any letter of credit. assessee's representative clarified that payment is obtained by bank discounting assessee's bills and that bank gives overdraft which would not be credited against discounted bills, but only against payment made by Sudan importer. He also invited our attention to note from Indian Embassy in Khartoum, which, inter alia, states that "exporters should exercise some caution as far as Sudanese market is concerned. In case o f bills for goods imported before 15-9-1979 commercial banks would endeavour to remit proceeds as and when foreign currency resources become available. Delays of 12-18 months are likely to occur before remittances take place". assessee's counsel stated that assessee had increased its price or sales to Sudan compared to sales to other places so as to cover this factor. He also clarified that interest has been calculated for period of one year because above note mentions that period from 12 to 18 months. 3. assessee had made actual claim of bank charges amounting to R s . 4,23,490 and out of this aforesaid amount of Rs. 3,40,000 was provision on account of interest according to assessee which may become payable on outstanding amounts to bank in future. Income-tax Officer found that this amount had not fallen due to bank in period relevant to assessment year 1980-81 and he has also recorded that assessee had stated vide its letter dated 31-1-1983 that this amount is only expected loss o n account of interest for periods after 31-12-1979 on amounts payable to bank on account of discounting of export sale bills. Income-tax Officer disallowed claim on ground that liability for interest had not arisen in relevant period. 4. Before CIT (Appeals), assessee contended that assessee was likely to incur this interest amount on account of delay which was likely t o occur and so liability for that interest had to be provided for. He had argued that this amount of interest had to be excluded from difference between sale price and purchase price because it could be assessed only in respect of real income relying on various authorities mentioned in CIT (Appeals)'s order. CIT (Appeals) rejected those contentions and so assessee is in appeal. 5. Before us also assessee's representative based his claim on real income theory. He argued that what he called risk was embedded in transaction from starting point of transaction, that is, export. He argued that assessee know at very start that exports to Sudan involved some risk and, therefore, assessee had to provide for it from beginning. He contended that calculation of interest was merely method of evaluating risk but actually it was not interest. It was risk for which assessee was providing and making claim for deduction. He argued that risk and possibility of loss to Sudan and, therefore this was trading loss for which assessee was making provision and consequent claim. He pointed out that assessee's method of accounting was mercantile and risk having been taken in relevant accounting period assessee was entitled to deduction in respect thereof. He relied upon of authorities in support of his aforesaid contentions. 6. learned departmental representative replied that said amount was merely provision for contingent liability because bank would charge only in next year. He argued that case law relied upon by assessee was not relevant and relied upon Tribunal's order, Cochin Bench, in case o f M/s. Tara Agencies, Cochin. assessee's representative replied that aforesaid decision of Tribunal had not considered submissions regarding risk element and real income which have been made this time. He also relied upon decision of Kerala High Court in case of Popular Kuries Ltd. v. CIT [1986] 159 ITR 519. 7. As stated above, question before us in regarding real nature and character of this claim of deduction. Is it interest simpliciter or is it amount which covers any risk? There is no doubt that if there is risk it is from starting point of transaction itself and consequently it would be matter of serious consideration to be taken into account for income of present assessment year. assessee's argument that amount has to be excluded from sale price on basis of real income theory would have some validity also if we were to accept contention regarding risk. In this connection we also appreciate argument of assessee that price of goods exported to Sudan is higher because of what he calls risk and so value of that risk has to be excluded from sale price. However, fundamental question remains regarding existence of this risk. We made strenuous efforts to ascertain what this risk was. In course of hearing, we asked assessee's representative to tell us what exactly is content of this risk, but we could not get clear answer from him. We are unable to find anything therein except factor of delay which can be translated in terms of interest as indeed it has been done. thus, basis of claim is only interest. Its true character is only interest. It is not like insurance claim where risk retains its character and money paid by insurer is only cover for risk. In that case risk remains risk; Whereas in this case claim of interest remains such from beginning to end. assessee's letter dated 31-1-1983 to Income- tax Officer also calls it interest for delay. assessee's representative has relied upon, inter alia, following authorities: relied upon, inter alia, following authorities: (1) CIT v. Nav Bharat Nirman (P.) Ltd. [1983] 141 ITR 723 (Delhi). (2) Popular Kuries Ltd.'s case (supra). In our view they are not relevant because in present case we have found that claim regarding risk has no substance. We also agree with reasoning of CIT (Appeals). Therefore, we confirm CIT (Appeals)'s order and reject this appeal. *** STANDARD TEA EXPORTS v. INCOME TAX OFFICER