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A.Yr.2001-02 deposits of varying periods ranging from 3 to 10 years. Interest on such recurring deposits is not payable at the end of previous year but is payable only on the maturity of the period for which the respective recurring deposits have been made. Such recurring deposits are made with the sole object of having funds in hand at the time of redemption of infrastructure development bonds issued by the assessee to raise funds for the purpose of pursuing its objects of providing infrastructure finance. Since both interest and principal are due and payable only upon maturity, the assessee did not account for any interest. According to the revenue, in case of a recurring deposit, interest is received and reinvested and as such interest is required to be taxed every year and not altogether at the time of maturity.

(iii) a banking company;
(iv) a co-operative bank other than a primary agricultural credit society or a primary co-operative agricultural and rural development bank;
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ITA No.388&464/Kol/2008 W.B.Infrastructure Development Finance Corpn.

A.Yr.2001-02

91. While computing the quantum of disallowance u/s 14A, the Assessee did not consider an aggregate sum of Rs. 198,80,09,710/- (Rs. 194,61,95,7101- in 1% Cumulative Preference Shares of Haldia Petrochemicals Ltd (HP L) and Rs. 4,18,14,000/- in Equity Shares of the Calcutta Stock Exchange Association Ltd (CSEAL)), being investments made by the Appellant pursuant to the directions desire of the Government of West Bengal, as investments for the purpose of Rule BD. The Appellant-Company is wholly owned by the Government of West Bengal. The Assessee is primarily engaged in the business of providing finance for infrastructural development in the State of West Bengal. For this purpose, the Assessee was required ITA No.388&464/Kol/2008 W.B.Infrastructure Development Finance Corpn.

CIT Vs. Winsome Textile Industries Ltd. 319 ITR 204 (P & H) CIT Vs. Corrtech Energy (P) Ltd. 372 ITR 97 (Guj.) CIT Vs. Shivam Motors Pvt. Ltd. 545 Taxmann.com 262 (All) ITA No.388&464/Kol/2008 W.B.Infrastructure Development Finance Corpn.
A.Yr.2001-02 Order dated 26.2.2009 of the Hon'ble Bombay High Court in ITA No.110 of 2009 in the case of CIT Vs. Delite Enterprise Ortder dated 12.9.2014 of the Bangalore ITAT in the case of M/S.Alliance Infrastructure Projects Pvt.Ltd. ITA No.220,2324, 1043 and 1217/Bang/2013. CIT Vs. Holcim India Pvt. Ltd. 57 Taxmann.com 28 (Del)