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Interest on unutilised government grant deposits was not taxable where the grant terms and accounts showed the funds and accrued interest belonged to the Government and the assessee remained only a custodian; the addition was deleted. TDS credit was not denied merely because the related interest was not taxable in the assessee's hands, as Rule 37BA credits tax to the deductee shown by the deductor, subject only to verification against any double claim; the matter was restored for that limited purpose. For MAT, interest on unutilised grant deposits and belated provident fund payment could not be added back unless covered by Explanation 1 to section 115JB, so those adjustments were deleted, while the provision for obsolete material was remitted for factual verification as to whether it was a provision or ascertained liability. Interest under section 234A could not be levied by reference to a revised return, because the provision applies only to delay in the original return; the levy was deleted.
Interest on unutilised government grant deposits was not taxable where the grant terms and accounts showed the funds and accrued interest belonged to the Government and the assessee remained only a custodian; the addition was deleted. TDS credit was not denied merely because the related interest was not taxable in the assessee's hands, as Rule 37BA credits tax to the deductee shown by the deductor, subject only to verification against any double claim; the matter was restored for that limited purpose. For MAT, interest on unutilised grant deposits and belated provident fund payment could not be added back unless covered by Explanation 1 to section 115JB, so those adjustments were deleted, while the provision for obsolete material was remitted for factual verification as to whether it was a provision or ascertained liability. Interest under section 234A could not be levied by reference to a revised return, because the provision applies only to delay in the original return; the levy was deleted.
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