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Issues Involved:
1. Taxability of interest income u/s 56 of the Income-tax Act, 1961. 2. Taxability of miscellaneous income u/s 56 of the Income-tax Act, 1961. Summary: 1. Taxability of Interest Income u/s 56: The primary issue was whether the interest income of Rs. 3,14,366 earned by the assessee on short-term deposits should be taxed under the head "Income from other sources" u/s 56 of the Income-tax Act, 1961. The assessee, a company engaged in the erection of a smelter for manufacturing ferro-manganese, had not commenced commercial production during the assessment year 1977-78. The assessee argued that the interest income should be adjusted against the interest paid on borrowed funds and capitalized as part of the construction expenses. The Income-tax Officer assessed the interest income as "Income from other sources," but the Commissioner of Income-tax (Appeals) and the Income-tax Appellate Tribunal upheld the assessee's treatment, stating that the interest income was part of a composite transaction aimed at reducing the burden of interest payments on borrowed funds. The court agreed with the Tribunal's view, noting that the interest income should be set off against the interest expenses and not be treated as income from other sources. 2. Taxability of Miscellaneous Income u/s 56: The second issue was whether the miscellaneous income of Rs. 2,742 from the sale of empty gunny bags should be taxed under the head "Income from other sources" u/s 56 of the Income-tax Act, 1961. The court held that the receipt from the sale of empty gunny bags could not be considered as a profit or revenue receipt, and thus, it should not be treated as income derived from other sources. Conclusion: The court answered the question in the affirmative, favoring the assessee and against the Revenue, concluding that neither the interest income nor the miscellaneous income should be taxed under the head "Income from other sources" u/s 56 of the Income-tax Act, 1961. There was no order as to costs.
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