Interest on Share Capital Deemed Capital Receipt, ITAT Overrules Income Classification, Citing Supreme Court Precedent.

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....Interest earned on share capital was treated as income, but the assessee argued that the interest was used for capital expenses as mandated by the Ministry of Ayush and was later converted into Share Capital Contribution of the Central Government. The assessee had made fixed deposits, and the interest earned belonged to the Central Government and was utilized as capital receipt with prior approval. The CIT(A) relied on the assessee showing interest as income from other sources, but the Supreme Court's judgment in Kedarnath Jute Mfg Co. Ltd vs CIT held that book entries are not relevant for computing total income. The CIT(A) also relied on CIT vs Pandian Chemicals Limited's case regarding interest earned on own free deposits, which was not applicable here. Considering the facts and legal principles, the ITAT allowed the assessee's appeal and set aside the impugned orders.....