Dismissing the appeal of the revenue the Court held that ; as per loan agreement executed between consortium of banks and assessee all disbursements were to be deposited in trust and retention account was to be subject to strict control and verification by senior lenders and all disbursements were to be utilized solely for purpose of implementation of project and no other purpose .Funds were thus inextricably linked to setting up of mega road projects and interest earned on such borrowed funds could not be classified as income from other sources . Accordingly  the  interest received prior to commencement of commercial operations of specified mega projects will be in nature of capital receipt and will be required to be set off against pre-operative expenditure capitalized under head capital work-in-progress and cannot be  taxed under head income from other sources.