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TMI Blog2016 (3) TMI 633X X X X Extracts X X X X X X X X Extracts X X X X ..... urity, the assessee has received an amount equal to the immaturity value of the bonds. Since the assessee has already paid interest to the previous bond holders, the difference amount between the interest received by the assessee on the maturity date and interest paid on the purchase date by the assessee was treated as income in the hands of the assessee. Further, while redeeming the bonds, the ICICI Ltd. has also done TDS on the maturity value minus face value. Since the assessee has ignored the premium paid on purchase of bonds and claimed the same also as interest, the ld. CIT(A) has rightly observed that it is not an allowable expenditure. Accordingly, the ld. CIT(A) correctly sustained the addition made by the Assessing Officer. Under ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... filed on 30.11.2000 as a returned filed in response to the notice under 148 of the Act. Subsequently, notice under section 143(2) of the Act was also issued on the assessee. Further, during the course of hearing, the assessee was asked to produce certain details and with regard to the purchase and sale of ICICI Bonds and the assessee has also submitted all the documents and the same were verified by the Assessing Officer. After verification of documents filed by the assessee and considering the submissions of the assessee, the Assessing Officer completed the assessment under section 143(3) r.w.s. 147 of the Act by assessing total taxable income of the assessee at ₹ 3,85,37,985/- by making various additions. 3. The assessee carried ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Premium Purchase (Rs.) 5,00,00,000 24,82,876.71 9,55,000 15,00,00,000 1,14,75,000.00 10,80,000 6. The assessee has already paid the interest components of ₹ 0.24 crores and ₹ 1.14 crores along with face value and premium to the previous bond holders ICICI Security Finance Co. on cum interest price basis. The Assessing Officer further observed that on the date of maturity, the assessee received an amount equal to the maturity value of the bonds ₹ 5.76 crores and ₹ 17.07 crores respectively. Since the assessee has already paid to the previous bond holder, the interest for the period up to the da ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... refore, the difference of income payable of ₹ 20,35,000/- was added to the income of the assessee under the head income from other sources . After considering the submissions of the assessee and also considering the facts of the case, the ld. CIT(A) has observed that the assessee has already paid the interest component of ₹ 0.24 crores and ₹ 1.14 crores along with the face value and premium on the date of maturity, the assessee has received an amount equal to the immaturity value of the bonds. Since the assessee has already paid interest to the previous bond holders, the difference amount between the interest received by the assessee on the maturity date and interest paid on the purchase date by the assessee was treated a ..... X X X X Extracts X X X X X X X X Extracts X X X X
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