https://www.taxtmi.com/caselaws?id=55293 Interest earned on short-term bank deposits of Government-contributed share capital was treated as diverted at source by overriding title in favour of the Government and therefore not taxable in the assessee's hands. The contribution was made for allotment of shares, and the surrounding resolutions and later Government letter required that any interest on temporarily parked funds be paid to the Government. The Tribunal applied the principle that income is excluded from the assessee's hands only where the obligation exists at the source; a post-receipt obligation would merely amount to application of income. Balance-sheet treatment and the Revenue's cited precedent did not change the real character of the receipt. en-us Sat, 02 Jan 1982 00:00:00 +0530 Sat, 27 Apr 2024 11:43:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=55293 Interest earned on short-term bank deposits of Government-contributed share capital was treated as diverted at source by overriding title in favour of the Government and therefore not taxable in the assessee's hands. The contribution was made for allotment of shares, and the surrounding resolutions and later Government letter required that any interest on temporarily parked funds be paid to the Government. The Tribunal applied the principle that income is excluded from the assessee's hands only where the obligation exists at the source; a post-receipt obligation would merely amount to application of income. Balance-sheet treatment and the Revenue's cited precedent did not change the real character of the receipt. Case-Laws Income Tax Sat, 02 Jan 1982 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=55293