Tribunal Rules on Interest Income Taxation and Penalty Amid Ownership Dispute Over Fixed Deposit Funds.

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....The Appellate Tribunal adjudicated on the issue of addition of interest income and penalty u/s 271(1)(c). The assessee contended that the interest income from a Fixed Deposit (FD) with the State Bank of India never crystallized due to a legal dispute over the ownership of the funds. The Tribunal held that where the ownership itself is in question, the decision to delete the addition becomes questionable. The assessee cannot be permanently excluded from taxation on interest earned from the FD. However, the assessee cannot be taxed on an asset over which it does not have conclusive ownership. The issue of final ownership is yet to be decided by the court. The Tribunal directed the Assessing Officer to re-adjudicate the taxation of interest in.........