HUF ownership principle governs taxability of compensation interest from ancestral land, not the individual's name on accounts.

Interest on delayed compensation for acquisition of ancestral agricultural land was treated as income of the HUF where the land formed ancestral coparcenary property. The Tribunal applied its earlier decision on the same family and similar facts, holding that the naming of an individual PAN or bank account did not change the real owner of the income. It also noted that the relevant HUFs had later disclosed the income and paid tax under the Income Declaration Scheme. The income was therefore taxable in the hands of the HUF and not in the hands of the individual member.

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Issues: Whether the interest income arising from compensation for acquisition of ancestral agricultural land was taxable in the hands of the individual assessee or in the hands of the Hindu Undivided Family.

Analysis: The dispute was covered by the earlier Tribunal decision on the same family and similar facts. The land was treated as ancestral coparcenary property, and the interest on delayed compensation was found to belong to the respective HUF and not to the individual member in whose name the amount was credited. The Tribunal also noted that the HUFs had subsequently disclosed the income and paid tax under the Income Declaration Scheme, and that no individual could appropriate HUF income in his own hands merely because the PAN or bank account was in individual status.

Conclusion: The income was held taxable in the hands of the HUF and not in the hands of the individual assessee.

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