TMI Blog2022 (10) TMI 301X X X X Extracts X X X X X X X X Extracts X X X X ..... ies below that till the final award was passed by the Arbitral Tribunal 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 - No substantial question of law arises. - ITA 376/2022, ITA ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... of. ITA 376/2022 ITA 377/2022 5. Present Income Tax Appeals have been filed challenging the common Impugned Order dated 5thOctober, 2020 passed by the Income Tax Appellate Tribunal ( ITAT ) in ITA Nos.262/Agra/2016 and 387/Agra/2017 for the Assessment Years 2012-13 2013-14. 6. Learned Counsel for the Appellant states that the ITAT has erred in deleting the additions of Rs.8, ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... this agreement was accepted by the Delhi High Court Mediation and Conciliation Centre on 8th April, 2015, pursuant to which a final order dated 9th April 2015 was passed by this Court. 8. Having perused the paper-book, this Court finds that in the present cases, the FDRs were made in the name of the respondent-assessee by virtue of a consensual order dated 7th October, 2021 passed by the Arbitr ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... llowing conditions:- a) The FDR shall soon on being ready would be handed over to the Presiding Arbitrator and shall remain in his custody unless otherwise ordered by the Tribunal. b) Though the FDR is in the name of the Respondent company, but the Bank holding the fixed deposit shall note that the amount of FDR is not to be released nor to be made available for use in any manner whatso ..... X X X X Extracts X X X X X X X X Extracts X X X X
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