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2004 (12) TMI 17 - HC - Income TaxNo material has been placed on record to show that there was any stipulation that the interest earned on such grant/aid if kept in fixed deposit in commercial banks would not accrue to the appellant but to the State Government. In fact the orders issued by the State Government were for treating the amount of interest. By treating it as a further grant, in fact is an application of money after it has been earned by the appellant and, therefore, the Tribunal was-justified in holding that the interest, in fact, was taxable at the hands of the appellant. The theory of real income is not applicable to the facts of the present case inasmuch as the interest has accrued to the appellant which it had retained for years together and only later on it has decided to convert a part of the amount of accumulated interest and not the whole of it towards its share capital – appeal dismissed
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