Tribunal corrects interest income figures in revenue's appeal, remands other issues back for adjudication.

Income-tax Officer, Ward-3 (3), Kolkata Versus M/s. PDP Steels Ltd.

Income-tax Officer, Ward-3 (3), Kolkata Versus M/s. PDP Steels Ltd. - TMI Issues:
- Appeal against Ld. CIT(A)'s order allowing relief to assessee under section 80IC
- Disallowance of interest income on fixed deposit, security deposit, and delayed payment from customers

Analysis:
1. The appeal was filed by the revenue against Ld. CIT(A)'s order granting relief to the assessee under section 80IC for the assessment year 2014-15. The assessee, engaged in manufacturing and trading of iron and steel products, claimed deduction under section 80IC. The revenue challenged the allowance of relief amounting to a specific sum related to interest income from various sources.

2. The Assessing Officer disallowed the deduction claimed by the assessee on interest income from fixed deposits, security deposits, and delayed payments from customers under section 80IC. The Ld. CIT(A) upheld the disallowance of interest income from fixed deposits but mistakenly mentioned a different figure. The Tribunal corrected this error and confirmed the disallowance of interest income from fixed deposits. The revenue's appeal on this issue succeeded.

3. Regarding the disallowance of interest earned on security deposits, the Tribunal noted conflicting arguments. The assessee contended that such income was integral to its manufacturing business, while the revenue argued against it. However, the Ld. CIT(A) did not decide on this issue. Consequently, the Tribunal set aside this matter for fresh adjudication by the Ld. CIT(A) to determine the eligibility of the interest earned on security deposits for deduction under section 80IC.

4. Concerning the interest income earned for delayed payment from customers, the assessee argued that such income was directly related to its business operations and should be considered as business income eligible for deduction under section 80IC. The Ld. CIT(A) did not address this issue either. Therefore, the Tribunal remanded this matter back to the Ld. CIT(A) for a fresh decision in accordance with the law after hearing both parties.

5. In conclusion, the revenue's appeal was allowed for statistical purposes, with the Tribunal addressing the correction of figures related to interest income from fixed deposits and remanding the issues of interest earned on security deposits and delayed payment income from customers back to the Ld. CIT(A) for proper adjudication.