The Tax Publishers2020 TaxPub(DT) 3384 (Mad-HC) : (2020) 427 ITR 0318 : (2021) 276 TAXMAN 0254

INCOME TAX ACT, 1961

Section 10A

Making of deposits with bank was a business decision taken in view of commercial expediency and the interest income earned incidentially could not be de-linked from profits and gains derived by undertaking engaged in export of articles and, therefore, assessee was entitled to 100% exemption or deduction under section 10A in respect of the interest income earned by it on the deposits made by it with the Banks in the ordinary course of its business.

Deduction under section 10A - Allowability - Interest earned on bank deposits -

Revenue by way of appeal before Hgih Court challenged decision of Tribunal allowing deduction/exemption under section 10A as regards interest earned on bank deposits. Held: Making of deposits with bank was a business decision taken in view of commercial expediency and the interest income earned incidentially could not be de-linked from its profits and gains derived by undertaking engaged in export of articles as envisaged under section 10A could not be taxed separately under section 56. Accordingly, assessee was entitled to 100% exemption or deduction under section 10A in respect of the interest income earned by it on the deposits made by it with the Banks in the ordinary course of its business.

REFERRED :

FAVOUR : In assessee's favour.

A.Y. : 2003-04



IN THE MADRAS HIGH COURT

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