Assessee was a co-operative bank and under liquidation with effect from 13-8-2002.  Post liquidation, assessee was not carrying out any business activity. Assessee through liquidator was to realize debt/assets for making further payment to creditors.  Assessee had received amount of interest income net of expenses in year under consideration for Rs. 6.53 crores post liquidation. The assessee set off against the brought forward business loss. The Assessing Officer has not allowed set off. Before CIT (A) the assessee contended that interest income was not taxable. CIT (A) has not accepted the claim of the asseessee. On appeal the Tribunal held that as per understanding with DICGCI, assessee was liable to make payment to DICGCI against amount recovered by it, therefore, amount to be received by assessee had to be paid firstly to DICGCI after making necessary provision for expenses in relation to liquidation and declaration of dividend. Tribunal held that since amount of interest in dispute was not an income of assessee, same could not have been made subject matter of tax in hands of assessee.  (AY. 2011-12)