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The High Court held that the ITAT's conclusion that the seized document GCL-HD-1 did not constitute incriminating material was a finding of fact. Therefore, it did not involve a substantial question of law, and the appeals filed by the Revenue were dismissed.
The Tribunal held that the ledger entries and statements recorded during the search did not constitute incriminating material for making additions in an unabated assessment. Therefore, the disallowance made under Section 40(a)(ia) was deleted.
The High Court held that interest earned from short-term deposits of unutilized capital subsidy, debt, and equity funds during the formative years of a project is inextricably linked to the project cost and should be treated as a capital receipt, not taxable income.