Held that where assessee-company had not commenced its business activities during relevant financial year and earned interest income on fixed deposits made by it in earlier years, interest income earned on fixed deposits pertaining to period prior to commencement of business was in nature of capital receipt and pre-operative expenses of assessee had to be adjusted with this “capital receipt” and only balance expense, needed to be amortized as per provisions of section 35D. (AY. 2015 -16)
DCIT v. BTW Atlanta Transformers India (P.) Ltd. (2024) 206 ITD 670 (Ahd) (Trib.)
S. 4 : Charge of income-tax-Interest on fixed deposit – Not commenced its business – Interest income earned on fixed deposits pertaining to period prior to commencement of business was in nature of capital receipt. [S. 28(i), 35D]