TMI Blog2014 (6) TMI 744X X X X Extracts X X X X X X X X Extracts X X X X ..... vindarajulu Chetty [1987 (2) TMI 3 - SUPREME Court] - the interest received is to be assessed on accrual basis year to year and not to be assessed in its entity in the year of receipt - AO is directed to apportion the interest among the 3 co-owners - The interest apportioned to the appellant shall be spread over the period of delay in paying the compensation - The share of interest accruing to the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... verification of this return and the accompanying document, it was found by the AO that assessee has only shown net agricultural income of Rs. 85,650/-, despite the fact that as per TDS certificate accompanying the return of income, the assessee has received interest of Rs. 15,29,242/- and Rs. 17,691/- during the year under appeal. This interest income was received by the assessee from the office ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... o be trifurcated among the three persons. Further the interest was received on account of delayed payment of compensation. Therefore, in the light of Apex Court judgments in the cases cited at 165 ITR 231 (supra), 181 ITR 400 (supra) and 181 ITR 408 (supra), the interest received is to be assessed on accrual basis year to year (and not to be assessed in its entity in the year of receipt) . 3.2. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... nterest accruing to the appellant for the year under consideration shall be assessed to tax. To that extent the addition stands upheld and the balance addition stands deleted. The appellant shall furnish the necessary working/details to the A.O. Thus this ground of appeal is partly allowed. 4. Since at the time of hearing neither any fault with the above finding of Ld. CIT(A) was pointed out n ..... X X X X Extracts X X X X X X X X Extracts X X X X
|