Diversion of income by overriding title defeats taxability of interest credited to development funds and allows promotional expenditure.

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....Interest differential credited to statutory development funds was treated as diverted at source under the scheme directions, so it was not taxable in the assessee's hands; the Tribunal followed its earlier orders in the assessee's own case and noted that the assessee acted only as a nodal or implementing agency. Promotional and developmental expenditure was also allowed because the assessee had been notified from financial year 2012-13, applicable from assessment year 2013-14, so the basis of disallowance failed. The Revenue's appeal was dismissed and the appellate order was upheld in full.....