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ITAT partially allows appeal, directing AO to re-examine multiple tax issues. Key holdings include: (1) Government grant of Rs. 150 crores transferred to implementing agency is not taxable income; (2) disallowed interest expenditure of Rs. 547.50 crores requires fresh assessment considering accounting treatment; (3) unexplained investment provisions under section 69 incorrectly invoked against state undertaking; (4) unrecorded rental income from National Housing Board to be verified with already accounted amounts; (5) brought forward business loss set-off to be re-examined; and (6) interest under sections 234A and 234B to be recomputed based on final income determination. Matter substantially restored to Assessing Officer for detailed re-evaluation.
ITAT partially allows appeal, directing AO to re-examine multiple tax issues. Key holdings include: (1) Government grant of Rs. 150 crores transferred to implementing agency is not taxable income; (2) disallowed interest expenditure of Rs. 547.50 crores requires fresh assessment considering accounting treatment; (3) unexplained investment provisions under section 69 incorrectly invoked against state undertaking; (4) unrecorded rental income from National Housing Board to be verified with already accounted amounts; (5) brought forward business loss set-off to be re-examined; and (6) interest under sections 234A and 234B to be recomputed based on final income determination. Matter substantially restored to Assessing Officer for detailed re-evaluation.
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