TMI Blog2006 (2) TMI 140X X X X Extracts X X X X X X X X Extracts X X X X ..... inked to the furnishing of the bank guarantees by the assessee to the Department of Telecommunications for obtaining a licence – That finding in our view concludes the controversy inasmuch as, if the deposits were indeed inextricably linked to the business of the assessee, the question whether the income accruing on the said deposits would constitute business income stands answered by the decision ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... assessee was required to provide finance and performance bank guarantees to the Department of Telecommunications. The assessee appears to have arranged these bank guarantees from IFCL, NICL and Lord Krishna Bank. These institutions had in connection with the furnishing of the guarantees required deposit of margin money by the assessee. Interest earned/accrued on these margin money deposits became ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... that view was placed upon two decisions of the Supreme Court in CIT v. Bokaro Steel Ltd. [1999] 236 ITR 315 and CIT v. Karnal Cooperative Sugar Mills Ltd. [2000] 243 ITR 2. A further appeal by the Revenue filed before the Tribunal having failed, the former is in appeal before us under section 260A of the Income-tax Act. We have heard Mr. Jolly, learned counsel for the Revenue, and perused the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... proposition that where the income in the nature of interest flows from deposits made by the assessee which deposits are in turn inextricably linked to the business of the assessee, the income derived on such deposits cannot be treated as income from other sources. In the light of what is said above no question of law, much less a substantial question of law arises for our consideration in this a ..... X X X X Extracts X X X X X X X X Extracts X X X X
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