TMI Blog1987 (4) TMI 91X X X X Extracts X X X X X X X X Extracts X X X X ..... Certain grants were received by the assessee from the Government and since the same were not utilised, funds were put in a bank on which interest was earned. The Revenue sought to tax such interest as it was of the view that interest income belonged the assessee. The assessee contended that as per direction of the Government interest income should be treated as further grant to the assessee from the Government. The assessee, therefore, contended that it cannot be said that the interest income was income of the assessee as actually it was the State Government which was entitled to such interest income but has given the direction that such income should be treated as further grant to the assessee for certain objectives provided therein. The ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... overnment. The authorities did not accept the contention. They pointed out that the amounts related to the asst. yr. 1978-79 and the assessee was covered by the Payment of Bonus Act, 1965 and the liability accrued in that year and not during the year under consideration. A similar view was taken in respect of payment of pension and other payments. The CIT considered the decision of the Hon'ble Supreme Court in the case of Kedarnath Jute Mfg. Co. Ltd. vs. CIT (1971) 82 ITR 363 (SC). Hence this appeal by the assessee. 6. It is submitted before us that the liability did accrue during the year under consideration on receipt of the order issued by the Accountant General, U.P. in respect of the various employees details of which have been give ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... f the CIT(A) to the extent that income from housing scheme shall be exempt as far as the scheme meant for scheduled castes and scheduled tribes was concerned. It is seen also that the claim of the assessee for exemption under s. 10(20A) also was considered by the Tribunal. The Tribunal noted that it considered the submissions of the assessee in respect of this section. It is pointed out that since it had considered the submission of the assessee in respect of the applicability of s. 10(26B), it did not think necessary to deal with the applicability of s. 10(20A) of the IT Act and, therefore, in view of the finding given by it, as mentioned earlier, the grounds relating to the exemption under s. 10(20A) has become infructuous and no finding ..... X X X X Extracts X X X X X X X X Extracts X X X X
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