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2021 (3) TMI 1045 - ITAT DELHIAddition on account of income earned on investment of corpus fund - income received from investments and credited to the corpus fund has been credited as per the directions of the Government of India - HELD THAT:- Respectfully following the earlier year precedent, we hold that amount cannot be treated as income of the assessee as it is a diversion of income by overriding title in view of letter from the Government of India, Ministry of Agriculture wherein it has been clearly stated that the corpus fund belongs to the Central and State Government and the interest thereto also belongs to the Government, and therefore, interest accrued on the corpus fund is required to be added in the corpus fund only. Accordingly, the appeal of the Revenue is dismissed. Disallowance u/s 14A - HELD THAT:- Once the assessee's income is to be computed u/s. 44 which relates to all insurance business which is a non obstante clause, therefore disallowance of Section 14A cannot be made.- Decided against revenue.
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