2012 (9) TMI 1207

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....Santhanakrishnan , C.A For the Respondent : Mr. K.E.B. Rangarajan, Jr.Standing Counsel ORDER Per Vikas Awasthy, JM: The appeal has been filed by the assessee impugning the order of the CIT(A)-VI, Chennai dated 20.12.2011. 2. The assessee is a State owned Transport Corporation. The assessee had filed its return of income on 30.10.2004 relevant to the assessment year 2004-05. The retu....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

..... 7.29 crores as trading receipts. Now, the assessee is in second appeal before the Tribunal assailing the order of the CIT(A). The only ground raised by the assessee in appeal before the Tribunal is addition of Rs. 7,29,00,000/- as trading receipts whereas funds were provided by the Government of Tamil Nadu to the assessee for payment of interest on account of belated payment of terminal benefits....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....sment year as it was outstanding opening balance as on 31.03.2004, therefore, the same cannot be treated as trading receipt for the assessment year 2004-05. The A.R. further contended that undisbursed balance amount has actually been adjusted fully against the students concession subsidy due to the assessee from the Government of Tamil Nadu in the subsequent years. The A.R. placed on record copy o....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....s balance of undisbursed amount received by the assessee from the State Government. The Assessing Officer vide assessment order dated 25.10.2007 has treated the said amount as trading receipt for the reason that the said amount was to be kept in separate account and not to be utilized for any other purposes. Since the assessee had utilized the undisbursed balance of Rs. 7.29 crores for working cap....