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ITAT held that interest on fixed deposits and related receipts were taxable as income from other sources because the maintenance clauses in the sale deed and co-developer agreement did not create diversion of income by overriding title; the funds and accrued interest remained under the assessee's control, so the use of interest for maintenance was only application of income after accrual. It also held that maintenance and administrative did not have the direct and exclusive nexus required for deduction against such interest income, so the disallowance was sustained. However, the Tribunal accepted that a claim under section 80P(2)(d) could not be denied merely because the return was filed under section 139(4), and directed allowance after hearing.
ITAT held that interest on fixed deposits and related receipts were taxable as income from other sources because the maintenance clauses in the sale deed and co-developer agreement did not create diversion of income by overriding title; the funds and accrued interest remained under the assessee's control, so the use of interest for maintenance was only application of income after accrual. It also held that maintenance and administrative did not have the direct and exclusive nexus required for deduction against such interest income, so the disallowance was sustained. However, the Tribunal accepted that a claim under section 80P(2)(d) could not be denied merely because the return was filed under section 139(4), and directed allowance after hearing.
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