Allowing the appeal the Court held  that the Tribunal expected actual commencement of the business after setting up of the necessary infrastructure and equipment. The Tribunal had ignored the issue as to whether financial transactions occurring during the period when the steps were initiated for commencement of the business could be taken into consideration for adjustment. The business for the Act would commence right from the stage of repairing and furnishing of property for being rented out and could not be treated as commenced only when the premises were actually let out to tenants. Interest income was directed to be assessed as business income, interest on borrowed funds  was directed to  be  Set-off of interest receipts against interest paid. (AY.1992-93)