Held, that the assessee had not recognised any revenue from its business operations and had capitalised the expenses incurred. The business funds lying idle with the assessee were invested in fixed deposits for earning income which was utilised in the business at the time of need. The decision to invest the idle funds lying with the assessee in fixed deposits had to be accepted as a decision taken by a prudent businessman keeping in view the commercial expediency. The assessee had temporarily parked its business funds in short-term deposits varying between three and nine months. When the need arose, the assessee encashed the fixed deposits and utilised the funds for its business purposes. Therefore, the interest income earned on fixed deposits had to be treated as business income of the assessee and had to be set off against the revenue expenses. However the income earned from mutual funds and interest from Income-tax refund, had to be taxed under the head Income from other sources. Relied  CIT v. Lok Holdings  (2009) 308 ITR 356 (Bom.)(HC). Tribunal also held that  neither the Assessing Officer nor Commissioner (Appeals) had given conclusive finding on the additional ground seeking to set off of income from other sources against the revenue expenses under section 71 of the Act. Therefore, the issue was restored to the Assessing Officer. (AY.2015-16)