CIT v. Shree Rama Multi Tech Ltd.( 2018) 403 ITR 426/165 DTR 137/ 302 CTR 90 / 255 Taxman 136 (SC) , www.itatonline.org

S. 4: Income chargeable to tax- Share application money- The Interest accrued from share application money has statutorily required to be kept in separate account and was being adjusted towards the cost of raising share capital against public issue expenses . [ S. 56, 145 ]

Dismissing the appeal of the revenue the Court held that ; interest accrued on account of deposit of share application money is not taxable income. Such interest is inextricably linked with the requirement to raise share capital and is thus adjustable towards the expenditures involved for the share issue. The fact that part of the share application money would normally have to be returned to unsuccessful applicants, and therefore, the entire share application money would not ultimately be appropriated by the Company, make no significant difference. The Interest earned from share application money has statutorily required to be kept in separate account and was being adjusted towards the cost of raising share capital against public issue expenses (  CIT v. Bokaro Steel Ltd (1999) 236 ITR 315 ( SC)( C A No. 6391 of 2013/ 8336 of 2013 dt. 24.04.2018)( AY. 1999-2000 to 2001-02)