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TMI Blog1986 (11) TMI 3X X X X Extracts X X X X X X X X Extracts X X X X ..... r our opinion under section 256(1) of the Income-tax Act, 1961 : " Whether, on the facts and in the circumstances of the case, the Tribunal was justified in holding that the interest paid in respect of borrowing from the Andhra Pradesh Industrial Development Corporation Limited by the assessee could not be allowed to be set off against the interest income earned by the assessee of Rs. 12,497 in t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... d stationery amounting in all to Rs. 4,46,022. Accordingly, the assessee filed a "nil" return. The Income-tax Officer was, however, of the opinion that the interest income earned by the assessee cannot be set off against the interest paid by it to the Andhra Pradesh Industrial Development Corporation Limited. This opinion was affirmed by the Commissioner of Income-tax (Appeals) and also by the Tri ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ounts. The amount upon which interest was paid to Andhra Pradesh Industrial Development Corporation Limited was raised by way of loan for setting up the plant and the interest income was earned on the contributions made by the shareholders towards the shares allotted to them. Both are distinct items and it is not possible to see any reasonable connection between them. Neither by section 57(iii) of ..... X X X X Extracts X X X X X X X X Extracts X X X X
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