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2021 (2) TMI 1328 - AT - Income TaxCorrect head of income - Interest on fixed deposits - taxable under the head "Other sources" as the appellant did not commence business activity - HELD THAT:- We find no substance in the assessee’s foregoing grievance. Case records indicate hat the assessee had to commence its commercial operations for the project(s) in issue from December 31st, 2013 relevant to AY.2014-15 whereas we are in AYs.2012-13 & 2013-14 only. The clinching fact as emerges therefore is that the assessee has sought the assessment of its interest income as ‘business income’ without having commenced its corresponding actual business activity at all in these two assessment years. We therefore find no reason to interfere with detailed reasoning extracted from the CIT(A)’s order in the preceding paragraphs. We thus decline assessee’s solitary grievance. Computation on netting basis - Assessee another plea that both the lower authorities ought to have adopted netting method by following the decision of ACG Associated Capsules Pvt. Ltd [2012 (2) TMI 101 - SUPREME COURT] than assessing the entire interest income u/s.57 of the Act - HELD THAT:- The fact remains that this issue has neither been examined in the course of assessment nor in the CIT(A)’s order. We therefore draw support from their lordships’ above decision and direct the Assessing Officer to finalise necessary computation on netting basis. No other ground has been pressed before us.
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