https://www.taxtmi.com/caselaws?id=760045 ITAT Mumbai held that the assessee qualified as a State instrumentality under Article 12 of the Constitution, applying the Som Prakash Rekhi criteria. The tribunal ruled that interest income from fixed deposits was exempt from taxation under Article 289(1), as the assessee functioned as an agent of the State. Since the Assessing Officer assessed this income under "income from other sources" rather than business income, Article 289(2) exception was inapplicable. The appeal was allowed, with other grounds becoming academic. en-us Fri, 27 Sep 2024 00:00:00 +0530 Fri, 11 Oct 2024 11:26:25 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=760045 ITAT Mumbai held that the assessee qualified as a State instrumentality under Article 12 of the Constitution, applying the Som Prakash Rekhi criteria. The tribunal ruled that interest income from fixed deposits was exempt from taxation under Article 289(1), as the assessee functioned as an agent of the State. Since the Assessing Officer assessed this income under "income from other sources" rather than business income, Article 289(2) exception was inapplicable. The appeal was allowed, with other grounds becoming academic. Case-Laws Income Tax Fri, 27 Sep 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=760045