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    <title>2026 (1) TMI 190 - ITAT MUMBAI</title>
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    <description>A body functioning as an instrumentality or agent of a State may claim constitutional immunity under Article 289(1) for its income, unless the income arises from trade or business carried on by or on behalf of the State under Article 289(2). On the stated facts, interest on fixed deposits was not taxable because it was not derived from any such trade or business. Grant-in-aid received for land acquisition, rehabilitation and infrastructure development was likewise not taxable, as it supported governmental and statutory functions; the alternative characterisation under section 2(24)(xviii) was not accepted.</description>
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    <pubDate>Wed, 31 Dec 2025 00:00:00 +0530</pubDate>
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      <link>https://www.taxtmi.com/caselaws?id=784434</link>
      <description>A body functioning as an instrumentality or agent of a State may claim constitutional immunity under Article 289(1) for its income, unless the income arises from trade or business carried on by or on behalf of the State under Article 289(2). On the stated facts, interest on fixed deposits was not taxable because it was not derived from any such trade or business. Grant-in-aid received for land acquisition, rehabilitation and infrastructure development was likewise not taxable, as it supported governmental and statutory functions; the alternative characterisation under section 2(24)(xviii) was not accepted.</description>
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      <pubDate>Wed, 31 Dec 2025 00:00:00 +0530</pubDate>
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