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TMI Blog2022 (10) TMI 301X X X X Extracts X X X X X X X X Extracts X X X X ..... , Sr. Standing Counsel with Ms. Adeeba Mujahid, Jr. Standing Counsel and Mr. Nikhil Jain, Advocate. Respondent Through: None. J U D G M E N T MANMOHAN, J (Oral): CM APPL.43152/2022 in ITA 376/2022 (Exemption) CM APPL.43154/2022 in ITA 377/2022 (Exemption) 1. Allowed, subject to all just exceptions. 2. Accordingly, the applications stand disposed of. CM APPL.43153/2022 in ITA 376/2022 CM A ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e name of the Assessee only and the share of the disputed parties in the interest will arise only after payment of due taxes. 7. Learned counsel for the appellant emphasizes that the dispute between the parties was with regard to 100 crores, whereas the amount deposited was in excess of Rs.190 crores. He also states that under the final settlement agreement dated 20th January, 2015 between the As ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... - (i) That the amount of Rs.1,90,25,12,694.09 which is lying in current account with Punjab National Bank in Tribunal's Bank Account No.2254002100017121 may be converted into a Fixed Deposit in the name of the Respondent company i.e. Global Heritage Venture Ltd. The fixed deposit shall be for a period of 60/61 days. This is being done solely for the consideration that the amount may earn interes ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ribunal determining the ownership of the fixed deposits and interest, it could not be said that the interest income had crystallized in the respondent's hands and the same cannot be held to be income of the respondent-assessee under Section 5(1) of the Income Tax Act, 1961 ('the Act'). 10. Accordingly, no substantial question of law arises for consideration in the present appeals and the same are ..... X X X X Extracts X X X X X X X X Extracts X X X X
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