2025 (11) TMI 1662

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....ere is a delay of 48 days in filing these appeals before ITAT, for which the Revenue has filed condonation petitions. 03. After perusing the condonation petition and hearing the rival parties, we find that the delay is for genuine, bonafide and reasonable cause and therefore, the delay in all four appeals is condoned and appeals are admitted for adjudication. 04. The common issue in both the appeals by the Revenue is against the deletion of addition made by the ld. CIT(A) as made by the ld. AO in respect of interest on FDR in the order passed u/s 143/254/143(3) of the Income-tax Act, 1961 (the Act) by the ld. Assessing Officer. As the facts are similar in all the appeals, we take ITA No. 1616/KOL/20124 for A.Y. 2011-12 as the lead cas....

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....e grounds relates to addition on account of interest on FDR amounting to Rs. 68,52,58,292. After filing the said submissions, the ITAT, Kolkata, A-Bench has decided a similar case vide its order dated 5 April 2023 where our client's appeal has been allowed. A copy of the said order dated 5 April 2023 is attached* for your kind ready reference. In this connection we draw your kind attention to Para 10 of the said order,which is reproduced below. "10. In the above profit and loss account interest income on FDR is not appearing since it has been deduced from the project cost 'work-in-progress'. As stated by Id. Counsel for the assessee the alleged sum has been shown as income in the computation of income filed in the incom....