TaxTMI 
TaxTMI 
2021 (1) TMI 781
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....given by the Ld. CIT(A) to the AO in the impugned orders are not being pressed. 3. Per contra, the Ld. D.R for the Department Shri Arup Chatterjee, Addl. CIT Sr. D.R accepted that other than the direction of Ld. CIT(A), there was only one issue in these appeals i.e. in respect of taxability of interest income. In the light of the aforesaid submissions, I note that the only issue that is being assailed before me is in respect of taxability of interest income, which the assessee has received in all the three assessment years. The Ld. Advocate for the assessee has submitted that he is not pressing the grounds regarding the directions given by the Ld. CIT(A) in the impugned orders. Since the issues are common, the appeal for AY 2012-13 is ta....
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.... observed that the assessee during the course of carrying on the business of construction projects had capitalized its direct and indirect expenses attributable to projects undertaken as work-in-progress and shown the same in the balance sheet. The AO noted that the assessee has claimed TDS credit in respect of interest income from banks. However, according to AO, corresponding interest income is not shown while computing total income for the year under consideration. The AO also noted that the assessee has interest income from fixed deposits in Punjab & Sindh Bank and M/s Assam Gramin Bikash Bank to the tune of Rs. 12,69,212/-. (the details of which he has reproduced at page 2 of the Assessment Order). According to AO, the interest income ....
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....est income was debited by the Appellant to the capital work in progress in the books of accounts of the Appellant. Thus, the contention of the Appellant is that the AO did not appreciate this aspect and has instead made the addition on account of interest income. Be that as it may be, it is noted that at the first instance, the Appellant had not offered the interest income for taxation and upon being so confronted by the AO and upon the aforesaid interest income being so added to its returned total income, during the course of appellate proceedings, The Apse ant had made an alternative claim of allowability of the interest cost under Section 57(1)(iii) contending that the said interest cost had been incurred wholly and exclusively ....
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....he assessee has preferred the ground no. 1 and 2 [supra] before me. 10. I have heard both the parties and perused the records. The Ld. Advocate for the assessee Shri Devraj Sahu has submitted that the assessee company is into the real estate development and construction of flats and had commenced the project named Tarun nagar project in this assessment year. According to Ld. Advocate, for this project, the assessee had acquired the land and got necessary approval for the construction of flats from Guwahati Municipal Development Authority (hereinafter referred to as the "GMDA"). According to Ld. Advocate, for the execution of the project / construction of flats at Tarun nagar Project, the assessee had taken loan of Rs. 3 crores (approxima....