https://www.taxtmi.com/caselaws?id=760967 ITAT Ahmedabad allowed the assessee's appeal regarding deduction under Section 80IA. The tribunal held that interest income from FDRs created as a direct consequence of loan conditions imposed by the bank for financing an infrastructure project qualifies as business income derived from eligible infrastructure business. The FDRs were not independent investments but integral to the business financing structure, making the interest income incidental to core infrastructure development activities. The tribunal distinguished the case from Tuticorin Alkali Chemicals Fertilisers, noting that unlike surplus funds parked in FDRs, these FDRs were specifically created for project financing. The AO's disallowance upheld by CIT(A) was set aside, and the Section 80IA(4) deduction was allowed. en-us Wed, 23 Oct 2024 00:00:00 +0530 Wed, 30 Oct 2024 08:32:35 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=760967 ITAT Ahmedabad allowed the assessee's appeal regarding deduction under Section 80IA. The tribunal held that interest income from FDRs created as a direct consequence of loan conditions imposed by the bank for financing an infrastructure project qualifies as business income derived from eligible infrastructure business. The FDRs were not independent investments but integral to the business financing structure, making the interest income incidental to core infrastructure development activities. The tribunal distinguished the case from Tuticorin Alkali Chemicals Fertilisers, noting that unlike surplus funds parked in FDRs, these FDRs were specifically created for project financing. The AO's disallowance upheld by CIT(A) was set aside, and the Section 80IA(4) deduction was allowed. Case-Laws Income Tax Wed, 23 Oct 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=760967