https://www.taxtmi.com/caselaws?id=398377 Interest earned by a statutory corporation on temporarily unutilised funds retained in a common fund was treated as business income because it was integrally linked to its core activity of deploying funds by way of loans and grants. The credit of that income to a common fund did not change its revenue character. Non-refundable grants made under the governing statute were held to be an essential business expenditure, and the source of funds used was immaterial. The payments were incurred wholly and exclusively for business purposes, so deduction under the Income-tax Act was allowed. The doctrine of diversion by overriding title did not apply because no grantee had a superior title to the funds before receipt. en-us Fri, 11 Sep 2020 00:00:00 +0530 Mon, 27 Apr 2026 16:04:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=398377 Interest earned by a statutory corporation on temporarily unutilised funds retained in a common fund was treated as business income because it was integrally linked to its core activity of deploying funds by way of loans and grants. The credit of that income to a common fund did not change its revenue character. Non-refundable grants made under the governing statute were held to be an essential business expenditure, and the source of funds used was immaterial. The payments were incurred wholly and exclusively for business purposes, so deduction under the Income-tax Act was allowed. The doctrine of diversion by overriding title did not apply because no grantee had a superior title to the funds before receipt. Case-Laws Income Tax Fri, 11 Sep 2020 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=398377