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ITAT ruled that interest income from fixed deposits marked as lien, conditional deposits from public offerings, deposits placed to comply with facility agreements, and deposits for working capital requirements should be treated as part of profits from core shipping activities under the Tonnage Tax Scheme. The Tribunal determined these deposits were inextricably linked to the assessee's sole business of operating qualifying ships, making the interest business income rather than separate income. ITAT directed the AO to treat all interest income as part of profits from core shipping activities. Additionally, the Tribunal upheld CIT(A)'s deletion of disallowances under section 14A r.w. Rule 8D and administrative expenditure incurred toward earning income from incidental activities, following precedents from earlier decisions.
ITAT ruled that interest income from fixed deposits marked as lien, conditional deposits from public offerings, deposits placed to comply with facility agreements, and deposits for working capital requirements should be treated as part of profits from core shipping activities under the Tonnage Tax Scheme. The Tribunal determined these deposits were inextricably linked to the assessee's sole business of operating qualifying ships, making the interest business income rather than separate income. ITAT directed the AO to treat all interest income as part of profits from core shipping activities. Additionally, the Tribunal upheld CIT(A)'s deletion of disallowances under section 14A r.w. Rule 8D and administrative expenditure incurred toward earning income from incidental activities, following precedents from earlier decisions.
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