Dismissing the appeal the Court held that unutilized funds of the project, before the commencement of the functional operation of the project, was invested by the assessee in fixed deposits and mutual funds as per the directions of the Government. A perusal of the Government order dated March 25, 2008, it was clear that the income generated out of earlier release of State Government for its project would have to be converted into State’s equity towards the project and could not be counted as income of the assessee.  There was no profit motive as the entire funds entrusted and the interest accrued therefrom had to be utilized only for the purpose of the scheme. Thus, it had to be capitalized and could not be considered as revenue receipts. (AY.2007-08, 2008-09)