The Tribunal dismissed the appeal and held that, there was a difference between setting up of business and commencement of business. Once the business is set up though it may not have yet commenced, the assessee would be eligible to claim the business expenditure as revenue expenditure. Any income arising after setting up of the business would be revenue in nature and assessable to tax. The interest income had accrued on fixed deposits made by the assessee and had accrued after the business has been set up. In fact, the assessee itself had offered a part of the interest income to tax but claimed to set off the remaining interest from capital work-in-progress on the reasoning that deposits were linked with the project. When the assessee had generated business income and claimed revenue expenditure including finance cost, mere fact that the deposits were linked with projects would not alter the character of the income after the business has been set up. The interest arose only because of creation of fixed deposits which was assessable only as income from other sources. (AY. 2011-12, 2012-13, 2014-15)