Assessee received interest from banks which was capitalized in the books of account as the interest accrued out of investment made in Banks from such borrowed Loan. AO assessed the interest as income from other sources .  CIT (A ) held  that the very purpose of constitution of Assessee was to act as a SPV created by Govt of India and Govt. of West Bengal in form of JV with equal equity participation for implementation of rapid transport infrastructure in Kolkata.Both Central and State Govts were to provide requisite finances for implementation of such project. Funds from Central and State Govts flew directly to assessee as equity and subordinate Debt/Loans. Objective was to create and maintain a fund for development of infrastructural assets on a continuing basis. There was no profit motive as entire fund entrusted and interest accrued there from on deposits in bank though in name of assessee had to be applied only for purpose of welfare of State as provided in guidelines accordingly the method adopted by the assessee was up held . On appeal by the revenue the Tribunal up held the finding of the CIT(A ).(AY.2010-11, 2011-12)