Dismissing the appeal of the revenue the Court held that ; interest earned before commencement of business operations was not liable to be taxed as same was eligible for deduction against public issue expenses incurred by company, interest income would go to reduce capital cost of project and was on capital account and cannot be assessed as income from other sources . Followed CIT v. Bokorao Steel Ltd ( 1999) 236 ITR 315 (SC) .( AY.2011-12)
PCIT v. Bank Note Paper Mill India (P.) Ltd. (2018) 256 Taxman 429 / ( 2019) 412 ITR 415 (Karn ) ( HC) Editorial: Order in, ITO v Bank Note Paper Mill India P.Ltd ( 2017) 56 ITR 226 (Bqng) (Trib) is affirmed .
S. 4 : Charge of income-tax – Interest on bank deposits out of share capital- Prior to commencement of business operations- Interest is liable to be assesses as income from other sources- interest income would go to reduce capital cost of project and was on capital account and same could not be taxed as income from other sources [ S.56 , 145 ]