2022 (4) TMI 324

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....eal. However, ld. Counsel for the assessee at the very outset submitted that grievance of the assessee revolves around a single issue, namely ld. CIT(Appeals) has erred in confirming the disallowance of Rs. 94,98,828/- claimed by the assessee under section 10(25) of the Income Tax Act. 2. Brief facts of the case are that the assessee has filed its return of income on 17.02.2017 declaring total income as 'NIL'. The Assessing Officer selected the case of the assessee for scrutiny assessment and a notice under section 143(2) was issued and served upon the assessee. A perusal of the accounts revealed to the ld. Assessing Officer that the assessee has claimed interest income of Rs. 94,98,828/- as exempt under section 10(25) of the Income Tax Ac....

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.... Tribunal. 5. We have duly considered the rival contentions and gone through the record carefully. Before embarking upon an inquiry on the facts of the present case, we deem it appropriate to the bear in mind the provisions of section 10(25) of the Income Tax Act. The relevant part reads as under: - "Chapter - III INCOMES WHICH DO NOT FORM PART OF TOTAL INCOME Incomes not included in total income. 10. In computing the total income of a previous year of any person, any income falling within any of the following causes shall not be included- (1) agricultural income; ***************************************** (25)(i) interest on securities which are held by, or are the property of, any provident fund to which the Provident Funds ....