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TMI Blog2018 (9) TMI 1821X X X X Extracts X X X X X X X X Extracts X X X X ..... T.A. No.179/Coch/2018 & S.P. No.17/Coch/2018 - - - Dated:- 24-9-2018 - S/SHRI CHANDRA POOJARI, AM GEORGE GEORGE K., JM For the Appellant : Shri Govind Shastri, CA For the Respondent : Smt. A.S. Bindhu, DR ORDER Per CHANDRA POOJARI, AM: This appeal filed by the assessee is directed against the order of the CIT(A), Trivandrum dated 23/3/2018 for the assessment year 2014-15. 2. The assessee has raised the following grounds: 1. The CIT(A) erred in confirming the action of the Assessing Officer in not setting off the interest income received during construction period against the expense during construction period and assessing it as income from other sources overlooking the fact that income earned on funds w ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ount of such revenue expenditure would be capitalized when the construction was completed. Further, as per 6D(i), the assessee had earned income from interest on deposits and interest income from Holding Company amounting to ₹ 14,10,38,438/- and ₹ 78,25,950/- respectively apart from having interest accrued but not due on fixed deposits at ₹ 61,27,128/- as mentioned in the balance sheet. The assessee submitted that it had incurred construction expenditure of ₹ 30,15,57,058/- from which it had set off the interest and tender fee received of ₹ 14,90,59,784/- and had shown the net balance of ₹ 15,24,97,274/- towards expenses incurred during construction. However, the Assessing Officer had not accepted the set ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... he Integrated Vaccine Project at Chengalpattu, Chennai and is to be utilized for the purpose of the project only and not for any other purpose. Further, it was submitted that the above letter is very important to decide the issue by the CIT(A) as he has observed in his order that no specific direction from the Ministry of Health and Family Welfare, Government of India and HLL Lifecare Ltd. while giving the fund that the surplus fund not immediately required for the implementation of the project can temporarily be deposited with banks and interest earned thereon would form part of the fund, has ever been made. Hence, the Ld. AR prayed for admission of the additional evidence. 8. The Ld. DR strongly opposed the admission of additional evid ..... X X X X Extracts X X X X X X X X Extracts X X X X
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