Fixed deposit interest and State grant-in-aid for government instrumentality held non-taxable; income-tax additions deleted under Articles 12/289.

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....Interest income on fixed deposits was held not taxable because the assessee, being wholly owned and constituted to perform governmental functions as an instrumentality of the State, qualifies as "State" under Article 12 read with Article 289 of the Constitution; consequently, such interest was treated as not derived from a taxable trade or business and the corresponding addition was deleted. Grant-in-aid received from the State Government was also held non-taxable since it was received by the assessee in its capacity as an arm of the State for executing public projects, and the related addition was directed to be deleted. - ITAT....