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    <title>2026 (5) TMI 1695 - ITAT AHMEDABAD</title>
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    <description>Interest earned by a co-operative bank under liquidation was held not to accrue as taxable income where the statutory scheme required all realisations to be applied first towards the Deposit Insurance and Credit Guarantee Corporation liability. The Tribunal found that section 21(2) of the Deposit Insurance and Credit Guarantee Corporation Act, 1961 left no dominion or discretion with the assessee over such receipts, so the amounts were diverted at source by overriding title in favour of the statutory creditor. Following the binding view in the assessee&#039;s own case, the interest income was excluded from tax in its hands and the Revenue&#039;s challenge failed.</description>
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    <pubDate>Wed, 22 Apr 2026 00:00:00 +0530</pubDate>
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      <description>Interest earned by a co-operative bank under liquidation was held not to accrue as taxable income where the statutory scheme required all realisations to be applied first towards the Deposit Insurance and Credit Guarantee Corporation liability. The Tribunal found that section 21(2) of the Deposit Insurance and Credit Guarantee Corporation Act, 1961 left no dominion or discretion with the assessee over such receipts, so the amounts were diverted at source by overriding title in favour of the statutory creditor. Following the binding view in the assessee&#039;s own case, the interest income was excluded from tax in its hands and the Revenue&#039;s challenge failed.</description>
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