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    <title>2023 (3) TMI 155 - JHARKHAND HIGH COURT</title>
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    <description>The court upheld the decisions of the CIT (Appeals) and ITAT, ruling that the interest income earned on fixed deposits by the Assessee, a Jharkhand State Government undertaking, did not constitute the Assessee&#039;s income under the Income Tax Act, 1961. The interest was deemed to be diverted by an overriding title before reaching the Assessee, as it was managed and returned to the government according to directives. The court dismissed the Revenue&#039;s appeals, affirming that executive guidelines could not override statutory provisions, and sustained the ITAT&#039;s orders in ITA No. 136/Ran/2018 and ITA No. 226/Ran/2016.</description>
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      <description>The court upheld the decisions of the CIT (Appeals) and ITAT, ruling that the interest income earned on fixed deposits by the Assessee, a Jharkhand State Government undertaking, did not constitute the Assessee&#039;s income under the Income Tax Act, 1961. The interest was deemed to be diverted by an overriding title before reaching the Assessee, as it was managed and returned to the government according to directives. The court dismissed the Revenue&#039;s appeals, affirming that executive guidelines could not override statutory provisions, and sustained the ITAT&#039;s orders in ITA No. 136/Ran/2018 and ITA No. 226/Ran/2016.</description>
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