Dismissing the appeal of the assessee the Court held that Fly ash did not belong to the assessee, but to its holding company–NTPC; assessee had only sold the fly ash and utilized part of the funds as mandated and made over the balance funds to NTPC; there is no infirmity in the decision of the Tribunal that the assessee had not earned any income on account of sale of fly ash, which was provided by NTPC. (AY. 2015-16)