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2014 (8) TMI 36 - HC - Income TaxInterest income allotted to be taxed on proportionate basis - Whether the Tribunal is right in holding that the interest income in the hands of the assessee allotted in the three years IDBI capital bonds is required to be taxed only on proportionate basis and that the CIT(A) was not justified in sustaining the addition made in the year in which it was received – Held that:- The entire interest received on Bonds is required to be included in the income for the Assessment Year in which the entire amount of interest was received - the upfront onetime payment of interest immediately on allotment is deferred revenue expenditure and the assessee creating asset on basis of interest for five years being paid in advance in first year and, the assets written off over period of debentures for five years continuing benefit to business of the assessee over the entire period, the liability is to be spread over period of debentures and, the entire amount of interest received as upfront one-time payment of interest immediately on allotment is included in the income for the first year in which the amount of interest is received - Following the decision in Rakesh Shantilal Mardia, Ahmedabad Versus Deputy Commissioner of Income Tax [2012 (9) TMI 521 - SUPREME COURT] - Decided against Revenue.
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