2022 (1) TMI 1478

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....by filing present appeal and cross objections sought to set aside the impugned order dated 28.03.2019 passed by Commissioner of Income Tax (Appeals) [hereinafter referred to as the CIT(A)] on the grounds inter alia that:- ITA No. 3566/M/2020 "1. Treating of interest income on non-earmarked fund as income from other sources - Rs. 1,86,73,436/- 2. Treating of rental income as income from other sources - Rs. 1,46,000/-." CO No. 64/M/2020 "1. On the facts and in the circumstances of the case and in law, the respondent prays that in case the interest income of Rs. 1,86,73,436 is held to be taxable under the head "Income from Other Sources" as prayed for by the Department in ground no. 2 of their appeal no. 3566/Mum/2019, then deduction....

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....nterest income as revenue receipt so as to bring it to tax as income from other sources. Declining the contention raised by the assessee company the AO proceeded to treat the interest income of Rs. 1,97,07,000/- on non-earmarked fund as income from other sources and brought the same to tax. The AO also made addition of Rs. 1,46,000/- received by the assessee company as rental income from Abhitek Developers Pvt. Ltd. which has been subjected to TDS but not shown in the computation of income or in the accounts as rental income and thereby framed the assessment at the total income of Rs. 1,98,53,000/- under section 143(3) of the Act. 4. The assessee carried the matter before the Ld. CIT(A) by way of filing the appeal who has partly allowed th....