2021 (7) TMI 1490

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.... R. Dipak For the Assessee: Shri M. Chandramouleswara Rao ORDER PER L.P. SAHU, A.M.: This appeal filed by the Revenue is directed against CIT(A) - 2, Hyderabad's order dated 04/12/2018 for AY 2015-16 involving proceedings u/s 143(3) of the Income-Tax Act, 1961; in short "the Act" on the following grounds of appeal: "1. In the facts and circumstances of the case, whether the CI....

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.... Telangana, filed its return of income for AY 2015-16 on 30/09/2015 electronically u/s 139(1) of the Act admitting total income of Rs. 147,16,83,030/-. Subsequently, the case was selected for scrutiny under CASS and assessment was completed u/s 143(3) of the Act on 22/12/2017 by determining the total income of Rs. 193,03,72,588/- by making the following additions: 1. Rs. 99,57,57,978/- be....

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....assessee earned an interest of Rs. 99,57,57,978/- from the deposits made with DISCOMS. However) the assessee instead of recognizing the same as revenue) credited it to (Deposits from GoAP for LIS account). Though the assessee did not offer the above interest to tax) it claimed the credit for the TDS made on the same) which is self-defeating/contradicting action on the part of the assessee. Further....

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....assessee's own case cited supra held as under: "5. After considering the rival contentions, we do not find any merit in Revenue grounds. As can be seen, the funds are clearly allocated for a specific purpose and assessee has no control over the funds, except utilizing them for the scheme for which it was granted. These funds are also kept separately and the interest was also accounted for....