TMI Blog1986 (11) TMI 3X X X X Extracts X X X X X X X X Extracts X X X X ..... : " Whether, on the facts and in the circumstances of the case, the Tribunal was justified in holding that the interest paid in respect of borrowing from the Andhra Pradesh Industrial Development Corporation Limited by the assessee could not be allowed to be set off against the interest income earned by the assessee of Rs. 12,497 in the assessment year 1978-79 ? " The assessment year concerne ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the assessee filed a "nil" return. The Income-tax Officer was, however, of the opinion that the interest income earned by the assessee cannot be set off against the interest paid by it to the Andhra Pradesh Industrial Development Corporation Limited. This opinion was affirmed by the Commissioner of Income-tax (Appeals) and also by the Tribunal in appeal. The Tribunal was of the opinion that such a ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... adesh Industrial Development Corporation Limited was raised by way of loan for setting up the plant and the interest income was earned on the contributions made by the shareholders towards the shares allotted to them. Both are distinct items and it is not possible to see any reasonable connection between them. Neither by section 57(iii) of the Income-tax Act, 1961, nor by applying the test of a pr ..... X X X X Extracts X X X X X X X X Extracts X X X X
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