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Interest arising from State Government funds advanced to an assessee is not taxable in the assessee's hands where the interest belongs to the State Government, including where the same issue has been determined for an earlier assessment year. Conversely, a signature bonus received on transferring developed power projects constitutes a revenue receipt when developing and transferring such projects forms part of the taxpayer's ordinary business and involves expenditure on surveys, testing and approvals. The distinction turns on beneficial ownership of the interest and the receipt's direct connection with regular business operations.
Interest arising from State Government funds advanced to an assessee is not taxable in the assessee's hands where the interest belongs to the State Government, including where the same issue has been determined for an earlier assessment year. Conversely, a signature bonus received on transferring developed power projects constitutes a revenue receipt when developing and transferring such projects forms part of the taxpayer's ordinary business and involves expenditure on surveys, testing and approvals. The distinction turns on beneficial ownership of the interest and the receipt's direct connection with regular business operations.
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