9911796707
TMI Blog2013 (9) TMI 1303X X X X Extracts X X X X X X X X Extracts X X X X ..... ent :- Ashish Raj Shukla,Ashish Raj Shukla,Pushpila Bishit,Raj Bali Shukla ORDER (Delivered by Hon'ble Dr. Satish Chandra, J.) Cause shown in the affidavit in support of the application to condone the delay is sufficient. Accordingly, the applications are allowed and the delay in filing the present appeals are hereby condoned. All the appeals have been filed by the Department under Section 260 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... h. So, the AO has rightly made the addition pertaining to the interest in the hands of the assessee. On the other hand, Sri Raj Bali Shukla, learned counsel for the assessee submits that the FRDs were purchased when the State was undivided. The State was divided on 01.04.2001. Thereafter, the assets of the two States were divided, as per the notification dated 13.02.2004 in the ratio of 46:54 betw ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... funds were also divided in the ratio of 46:54%. The Tribunal vide its impugned order has observed that the interest income has to be divided in the ratio of 46:54% and only 46% thereof has to be taxed in the hands of the present assessee. The rest of 54% is taxable in the hands of Uttaranchal Forest Development Corporation. In view of the aforesaid notification and above discussion, we find no re ..... X X X X Extracts X X X X X X X X Extracts X X X X
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