CIT v. Bangalore Metro Rail Corporation Ltd. (2022) 285 Taxman 491 (Karn.)(HC)

S. 4 : Charge of income-tax-Interest-Interest accrued had to be utilized only for purpose of scheme-Not assessable as revenue receipt.

Court held that  income generated out of earlier release of funds by Government to assessee before commencement of project would have to be converted into State’s equity towards project and therefore could not be counted as income of assessee. There was no profit motive as entire fund entrusted and interest accrued therefrom had to be utilized only for purpose of scheme hence  the  funds had to be capitalized and could not be considered as revenue receipts. (AY.2007-08, 2008-09)