CIT v. Motorola India Electronics (P.) Ltd.

46 Taxmann.com 167High Court2014#1478 most cited

What is CIT v. Motorola India Electronics (P.) Ltd. authority for?

Interest income derived from funds of an undertaking, such as from FDRs or EEFC accounts, forms part of the "profits of the business of the undertaking" and is eligible for deduction under Sections 10A and 10B, provided there is a direct nexus with the business. This deduction applies to the entire income from the business of the undertaking, not solely to profits from export activities.

77

judgments rely on this decision, according to BharatTax’s citation analysis of 366,470 Indian tax judgments — from 2015 to 2026.

Also referred to as

CIT v. Motorola India Electronics (P.) Ltd. · Section 10A deduction · Section 10B deduction · profits of the business of the undertaking · interest on fixed deposits · EEFC account interest · direct nexus · export oriented unit · income eligible for deduction · business income eligibility

Also reported as

225 Taxmann 11

Sections most often in play

Section 10AASection 143(3)Section 10ASection 115-OSection 234BSection 10BSection 250Section 37(1)
Read the full judgment

Issues it is cited on

section 10basection 75export oriented unitconvertible foreign exchangeinterest on outstanding receivablessection 10bsection 80hhcinitial assessment yearsection 80hsection 80hhtransfer pricing ordersection 10aa

Judgments citing CIT v. Motorola India Electronics (P.) Ltd.

DCIT, Circle-12(1), Kolkata vs. M/S Hindusthan Gum & Chemicals Ltd., Kolkata

In the result, the appeal of the assessee is partly allowed for statistical purposes and the appeal of the revenue is dismissed

ITA 1601/KOL/2016[2010-2011]Status: DisposedITAT Kolkata14 Feb 2018AY 2010-2011

Bench: Hon’Ble Shri M.Balaganesh, Am & Shri S.S.Viswanethra Ravi, Jm] I.T.A No. 1410/Kol/2016 Assessment Year : 2010-11 Hindustan Gum & Chemicals Ltd. -Vs- Dcit, Circle-12(1), Kolkata [Pan: Aaach 7214 E] (Appellant) (Respondent) I.T.A No. 1601 /Kol/2016 Assessment Year : 2010-11 Dcit, Circle-12(1), Kolkata -Vs- Hindustan Gum & Chemicals Ltd. [Pan: Aaach 7214 E] (Appellant) (Respondent) For The Appellant : Shri J.P. Khaitan, Sr. Advocate Shri Vinod Sharma, Ca For The Respondent : Shri Sallong Yaden, Addl. Cit

For Appellant: Shri J.P. Khaitan, Sr. AdvocateFor Respondent: Shri Sallong Yaden, Addl. CIT
Section 10BSection 143(3)Section 14A

…s, as such, no scope for any controversy that part of the money was earned from interest and not from export. This question came up before the Karnataka High Court and was answered in the case of CIT vs. Motorola India Electronics (P.) Ltd. reported in [2014] 46 Taxmann.com 167 (Karnataka) as follows : “In the instant case, the assessee is a 100% EOU, which has exported software and earned the income. A portion of that income is included in EEFC account. Yet another portion of the amount is invested within the country by way of fixed deposits, another portion of the amount is invested by way of loan to sister con…

Hindustan Gum & Chemicals Ltd., Kolkata vs. The DCIT, Cir-12(1), Kolkata

In the result, the appeal of the assessee is partly allowed for statistical purposes and the appeal of the revenue is dismissed

ITA 1410/KOL/2016[2010-11]Status: DisposedITAT Kolkata14 Feb 2018AY 2010-11

Bench: Hon’Ble Shri M.Balaganesh, Am & Shri S.S.Viswanethra Ravi, Jm] I.T.A No. 1410/Kol/2016 Assessment Year : 2010-11 Hindustan Gum & Chemicals Ltd. -Vs- Dcit, Circle-12(1), Kolkata [Pan: Aaach 7214 E] (Appellant) (Respondent) I.T.A No. 1601 /Kol/2016 Assessment Year : 2010-11 Dcit, Circle-12(1), Kolkata -Vs- Hindustan Gum & Chemicals Ltd. [Pan: Aaach 7214 E] (Appellant) (Respondent) For The Appellant : Shri J.P. Khaitan, Sr. Advocate Shri Vinod Sharma, Ca For The Respondent : Shri Sallong Yaden, Addl. Cit

For Appellant: Shri J.P. Khaitan, Sr. AdvocateFor Respondent: Shri Sallong Yaden, Addl. CIT
Section 10BSection 143(3)Section 14A

…s, as such, no scope for any controversy that part of the money was earned from interest and not from export. This question came up before the Karnataka High Court and was answered in the case of CIT vs. Motorola India Electronics (P.) Ltd. reported in [2014] 46 Taxmann.com 167 (Karnataka) as follows : “In the instant case, the assessee is a 100% EOU, which has exported software and earned the income. A portion of that income is included in EEFC account. Yet another portion of the amount is invested within the country by way of fixed deposits, another portion of the amount is invested by way of loan to sister con…

Value Labs LLP, Hyd, Hyderabad vs. DCIT, Circle-8(1), Hyderabad

In the result, grounds pertaining to ‘other income’ are considered allowed and grounds pertaining to interest income are considered allowed for statistical purposes

ITA 392/HYD/2016[2009-10]Status: DisposedITAT Hyderabad24 Jan 2018AY 2009-10

Bench: Smt. P. Madhavi Devi & Shri B. Ramakotaiah

For Appellant: Shri P. Murali Mohan Rao, ARFor Respondent: Smt. N. Swapna, DR
Section 10Section 10ASection 10BSection 56

…IN THE INCOME TAX APPELLATE TRIBUNAL HYDERABAD BENCHES “B”, HYDERABAD BEFORE SMT. P. MADHAVI DEVI, JUDICIAL MEMBER AND SHRI B. RAMAKOTAIAH, ACCOUNTANT MEMBER I.T.A. No. 392/HYD/2016 Assessment Year: 2009-10 M/s. ValueLabs LLP, Deputy Commissioner HYDERABAD Vs of Income Tax, [PAN: AAEFV9532G] Circle-8(1), HYDERABAD (Appellant) (Respondent) For Assessee : Shri P. Murali Mohan Rao, AR For Revenue : Smt. N. Swapna, DR Date of Hearing : 04-01-2018 Date of Pronouncement : 24-01-2018 O R D E R PER B. RAMAKOTAIAH, A.M. : This is an appeal by assessee against the order of the Commissioner of Income Tax (Appeals)-9, Hyd…

ACIT, New Delhi vs. M/S Vineet Sood & Sons (HUF), New Delhi

In the result, the appeal of the revenue is dismissed

ITA 6205/DEL/2015[2007-08]Status: DisposedITAT Delhi25 Aug 2017AY 2007-08

Bench: Shri G.D. Agrawal & Shri Amit Shuklain Ita No. 6205/Del/2015 Assessment Year: 2007-08 Acit Vs. Vineet Sood & Sons (Huf), Circle 28(1), G-53, Sarita Vihar, New New Delhi Delhi (Applicant) (Respondent) (Pan: Aaahv3031Q)

For Appellant: Shri Rakesh Verma, CAFor Respondent: Shri Atiq Ahmed, Sr. DR
Section 10BSection 143(1)Section 143(3)Section 147Section 263

…ITA No. 6205/Del/2015 Assessment Year: 2007-08 IN THE INCOME TAX APPELLATE TRIBUNAL (DELHI BENCH “G” BENCH NEW DELHI) BEFORE SHRI G.D. AGRAWAL, PRESIDENT & SHRI AMIT SHUKLA, JUDICIAL MEMBER In ITA No. 6205/Del/2015 Assessment Year: 2007-08 ACIT Vs. Vineet Sood & Sons (HUF), Circle 28(1), G-53, Sarita Vihar, New New Delhi Delhi (Applicant) (Respondent) (PAN: AAAHV3031Q) Revenue by: Shri Atiq Ahmed, Sr. DR Assessee by: Shri Rakesh Verma, CA Date of hearing 22/08/2017 Date of pronouncement 25/08/2017 ORDER PER AMIT SHUKLA, JUDICIAL MEMBER: The aforesaid appeal has been filed by the Revenue against impugned order…

DCIT, Bangalore vs. M/S Toshiba Software (India) Pvt. Ltd., Bangalore

Appeal is dismissed and the

ITA 808/BANG/2016[2010-11`]Status: DisposedITAT Bangalore09 Jun 2017

Bench: Shri. A. K. Garodia & Shri. Lalit Kumari.T.A No.808/Bang/2016 (Assessment Year : 2010-11) Joint Commissioner Of Income-Tax (Osd), Circle -12(4), Bengaluru .. Appellant V. M/S. Toshiba Software (India) P. Ltd, (Erstwhile Toshiba Embedded Software (India) P Ltd, No.3A, “Essae Vishnavi Solitaire”, 3Rd Block, Koramangala, Bengaluru .. Respondent Pan : Aagcs4693C

For Appellant: Shri. K. R. Vasudevan, AdvocateFor Respondent: Shri. M. K. Biju, JCIT
Section 10A

…ITA.808 & 748/Bang/2016 Page - 1 IN THE INCOME TAX APPELLATE TRIBUNAL BENGALURU BENCH 'C', BENGALURU BEFORE SHRI. A. K. GARODIA, ACCOUNTANT MEMBER AND SHRI. LALIT KUMAR, JUDICIAL MEMBER I.T.A No.808/Bang/2016 (Assessment Year : 2010-11) Joint Commissioner of Income-tax (OSD), Circle -12(4), Bengaluru .. Appellant v. M/s. Toshiba Software (India) P. Ltd, (erstwhile Toshiba Embedded Software (India) P Ltd, No.3A, “Essae Vishnavi Solitaire”, 3rd Block, Koramangala, Bengaluru .. Respondent PAN : AAGCS4693C I.T.A No.748/Bang/2016 (Assessment Year : 2010-11) (By the Assessee) Assessee by : Shri. K. R. Vasudevan, Advo…

DCIT, Bangalore vs. M/S Ocwen Financial Solutions Pvt. Ltd., Bangalore

In the result, the appeal of revenue is allowed for statistical purpose

ITA 863/BANG/2016[2010-11]Status: DisposedITAT Bangalore19 May 2017AY 2010-11

Bench: Shri Vijay Pal Rao & Shri Inturi Rama Rao

For Appellant: Shri G. Kamaldhar, Standing CounselFor Respondent: Shri Tanmayee Rajkumar, Advocate
Section 10ASection 10B

…IN THE INCOME TAX APPELLATE TRIBUNAL BANGALORE BENCH ‘ B ’ BEFORE SHRI VIJAY PAL RAO, JUDICIAL MEMBER AND SHRI INTURI RAMA RAO, ACCOUNTANT MEMBER I.T. A. No.863/Bang/2016 (Assessment Year : 2010-11) Dy. Commissioner of Income Tax, Circle 5(1)(2), Bangalore. …. Appellant. Vs. M/s. Ocwen Financial Solutions Pvt. Ltd., Pritech Park, Block No.12, 5th Floor, B Wing, Bellandur Vill., Sarjapur Marathahalli Ring road, Bangalore-560 103. ….. Respondent. PAN AAACO 3764E Appellant By : Shri G. Kamaldhar, Standing Counsel. Respondent By : Shri Tanmayee Rajkumar, Advocate. Date of Hearing : 04.04.2017. Date of Pronoun…

M/S I2 Technolgoies Software Pvt Ltd, Bangalore vs. Commissioner of Income Tax (Appeals)IV, Bangalore

In the result, the appeal of the revenue is partly allowed for statistical

ITA 1207/BANG/2014[2003-04]Status: DisposedITAT Bangalore21 Apr 2017AY 2003-04

Bench: Shri A. K. Garodia & Shri Laliet Kumar

For Appellant: Shri Arvind Sonde, AdvocateFor Respondent: Shri G.R.Reddy, CIT –I
Section 92C

…IT Act, 1961 should be allowed in respect of interest and Misc. income earned by the assessee. In this regard, he placed reliance on a judgment of Hon’ble Karnataka High Court rendered in the case of CIT Vs Motorola India Electronics (P) Ltd. as reported in 46 Taxmann.com 167(Kar.) He submitted a copy of this judgment and he has drawn our attention to para-8 thereof. After reading this Para of the judgment, it was pointed out by the Bench that in that case, a categorical finding has been given by the Hon’ble Karnataka High Court that there is direct nexus between interest income and income of the business…

DCIT, Cir-12, Kolkata vs. M/S Hindustan Gums & Chemical Ltd., Kolkata

In the result, the appeal of the assessee in ITA No

ITA 752/KOL/2014[2008-2009]Status: DisposedITAT Kolkata08 Mar 2017AY 2008-2009

Bench: Shri M. Balaganesh, Am & Shri Partha Sarathi Chaudhury, Jm]

For Appellant: S/Shri J. P. Khaitan, Sr. Adv. & Sanjay Bhaumik, AdvFor Respondent: Shri S. S. Alam, JCIT, Sr. DR
Section 143(3)Section 43B

…s, as such, no scope for any controversy that part of the money was earned from interest and not from export. This question came up before the Karnataka High Court and was answered in the case of CIT vs. Motorola India Electronics (P.) Ltd. reported in [2014] 46 Taxmann.com 167 (Karnataka) as follows : “In the instant case, the assessee is a 100% EOU, which has exported software and earned the income. A portion of that income is included in EEFC account. Yet another portion of the amount is invested within the country by way of fixed deposits, another portion of the amount is invested by way of loan to sister con…

Hindustan Gum & Chemicals Ltd., Kolkata vs. The DCIT, Cir-12, Kolkata

In the result, the appeal of the assessee in ITA No

ITA 462/KOL/2014[2008-2009]Status: DisposedITAT Kolkata08 Mar 2017AY 2008-2009

Bench: Shri M. Balaganesh, Am & Shri Partha Sarathi Chaudhury, Jm]

For Appellant: S/Shri J. P. Khaitan, Sr. Adv. & Sanjay Bhaumik, AdvFor Respondent: Shri S. S. Alam, JCIT, Sr. DR
Section 143(3)Section 43B

…s, as such, no scope for any controversy that part of the money was earned from interest and not from export. This question came up before the Karnataka High Court and was answered in the case of CIT vs. Motorola India Electronics (P.) Ltd. reported in [2014] 46 Taxmann.com 167 (Karnataka) as follows : “In the instant case, the assessee is a 100% EOU, which has exported software and earned the income. A portion of that income is included in EEFC account. Yet another portion of the amount is invested within the country by way of fixed deposits, another portion of the amount is invested by way of loan to sister con…

Mrs. Sashi Sadh, New Delhi vs. ITO, New Delhi

In the result, appeal of the Revenue is dismissed

ITA 6203/DEL/2013[2010-11]Status: DisposedITAT Delhi30 Jun 2016AY 2010-11

Bench: Sh. H.S. Sidhu & Sh. O.P. Kantassessment Year: 2010-11 Mrs. Sashi Sadh, 52/12, C.R. Park, Vs. Income Tax Officer, Ward-23(2), New Delhi New Delhi Gir/Pan : Amlps4154L (Appellant) (Respondent)

Section 10Section 10BSection 143(1)Section 143(2)

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH: ‘G’: NEW DELHI BEFORE SH. H.S. SIDHU, JUDICIAL MEMBER AND SH. O.P. KANT, ACCOUNTANT MEMBER Assessment Year: 2010-11 Mrs. Sashi Sadh, 52/12, C.R. Park, Vs. Income Tax Officer, Ward-23(2), New Delhi New Delhi GIR/PAN : AMLPS4154L (Appellant) (Respondent) Appellant by Sh. R.K. Singh, Adv. Respondent by Smt. Anima Barnwal, Sr.DR Date of hearing 27.06.2016 Date of pronouncement 30.06.2016 ORDER PER O.P. KANT, A.M.: This appeal by the assessee is directed against the order dated 28.03.2013 of learned Commissioner of Income Tax(Appeals)-XXIII, New Delhi, for the assess…

Airline Financial Support Services (India) Ltd ( Amalgamated With Tata Consultancy Services Ltd), Mumbai vs. DCIT 3(1), Mumbai

In the result, both appeals of the assessee are allowed

ITA 2549/MUM/2012[2001-02]Status: DisposedITAT Mumbai31 May 2016AY 2001-02
For Appellant: Shri Dinesh VyasFor Respondent: Shri B.D.Naik
Section 10ASection 271(1)Section 271(1)(c)Section 80H

…of Syntel Limited ( ITA Nos. 1974,1976,1978 of 2009) (Bombay High Court) and also on the decision of Mumbai Tribunal in the case of J.P. Morgan Service P.Ltd.( ITA No. 8987/Mum/2010 and 7822/Mum/2011) (Mumbai ITAT) and Motorola India Electronics (P) Limited (225 Taxmann 11) (Karnataka High Court). 5. On the other hand, ld. DR relied on the order of lower authorities. 6. We have considered rival contentions and carefully gone through the orders of authorities below and also deliberated on the judicial pronouncements cited by ld. AR. We had also deliberated on the judicial pronouncements referred by lower authorit…

Airline Financial Support Services (India) Ltd ( Amalgamated With Tata Consultancy Services Ltd), Mumbai vs. DCIT 3(1), Mumbai

In the result, both appeals of the assessee are allowed

ITA 2547/MUM/2012[2003-04]Status: DisposedITAT Mumbai31 May 2016AY 2003-04
For Appellant: Shri Dinesh VyasFor Respondent: Shri B.D.Naik
Section 10ASection 271(1)Section 271(1)(c)Section 80H

…of Syntel Limited ( ITA Nos. 1974,1976,1978 of 2009) (Bombay High Court) and also on the decision of Mumbai Tribunal in the case of J.P. Morgan Service P.Ltd.( ITA No. 8987/Mum/2010 and 7822/Mum/2011) (Mumbai ITAT) and Motorola India Electronics (P) Limited (225 Taxmann 11) (Karnataka High Court). 5. On the other hand, ld. DR relied on the order of lower authorities. 6. We have considered rival contentions and carefully gone through the orders of authorities below and also deliberated on the judicial pronouncements cited by ld. AR. We had also deliberated on the judicial pronouncements referred by lower authorit…

Duflon Polymers P. Ltd, Mumbai vs. Addl CIT 8(1), Mumbai

In the result, appeal is partly allowed

ITA 275/MUM/2011[2005-06]Status: DisposedITAT Mumbai13 May 2016AY 2005-06

Bench: Shri Saktijit Dey & Shri Ramit Kochar

For Appellant: Shri Deepak TralshwalaFor Respondent: Shri Mukesh Jain
Section 10BSection 234BSection 36(1)(iii)

…IN THE INCOME TAX APPELLATE TRIBUNAL “D” BENCH, MUMBAI BEFORE SHRI SAKTIJIT DEY, JUDICIAL MEMBER AND SHRI RAMIT KOCHAR, ACCOUNTANT MEMBER ITA no.275/Mum./2011 (Assessment Year : 2005–06) M/s. Duflon Polymers Pvt. Ltd. 3, Neeldhara Apartments Shradhanand Extension Road ……………. Appellant Vile Parle (E), Mumbai 400 057 PAN – AAACD1668G v/s Addl. Commissioner of Income Tax ……………. Respondent Circle–8(1), Mumbai Assessee by : Shri Deepak Tralshwala Revenue by : Shri Mukesh Jain Date of Hearing – 04.05.2016 Date of Order – 13.05.2016 O R D E R PER SAKTIJIT DEY, J.M. The aforesaid appeal of the assessee is directed…

Riviera Home Furnishing vs. Tax Range 15

The appeal is allowed in the above terms, but with no order as to costs

ITA/459/2015HC Delhi19 Nov 2015
Section 10BSection 143(2)Section 260A

…before the Karnataka High Court in CIT v. Motorola India 2015:DHC:9442-DB ITA No.459/2015 Page 4 of 12 Electronics Pvt. Ltd. (2014) 46 Taxmann.com 167 (Kar).The said appeal before the Karnataka High Court was by the Revenue challenging an order passed by the ITAT which held that the interest payable on FDRs was part of the profits of the business of the undertaking and therefore includible in the income eligible for deduction Sections 10A ad 10B of the Act. There the Assessee had e…

DCIT, Gurgaon vs. M/S. Q.H. Talbros Ltd., Gurgaon

In the result, both the appeals filed by the Revenue are dismissed

ITA 1320/DEL/2013[2008-09]Status: DisposedITAT Delhi04 Nov 2015AY 2008-09

Bench: Shri Inturi Rama Rao & Ms. Suchitra Kambleassessment Year: 2007-08 Acit, Circle-2, Vs. M/S Qh Talbros Ltd., Plot No. 400, Gurgaon Udyog Vihar, Phase-Iii, Gurgaon (Pan: Aaaco2191D) (Appellant) (Respondent) & Assessment Year: 2008-09 Dcit, Circle-2, Vs. M/S Qh Talbros Ltd., Plot No. 400, Gurgaon Udyog Vihar, Phase-Iii, Gurgaon (Pan: Aaaco2191D) (Appellant) (Respondent) Appellant By :Smt. Anjula Jain, Sr. Dr Respondent By : Sh. V.K. Aggarwal, Ar Date Of Hearing: 29.10.2015 Date Of Pronouncement: 04.11.2015 Order Per Inturi Rama Rao, A.M.: The Present Appeals Filed By The Revenue Are Directed Against The Orders Of Cit(A), Faridabad, Dated 27.12.2011 & 20.12.2012 Passed For The Assessment Years 2007-08 & 2008-09 Respectively. The Revenue Raised The Following Grounds Of Appeal In Ita No. 1321/Del/2012:

For Appellant: Smt. Anjula Jain, Sr. DRFor Respondent: Sh. V.K. Aggarwal, AR
Section 10BSection 115JSection 154Section 36(1)(iii)

…at would arise is whether the interest on the FDRs could form part of the ‘profits of the business of the undertaking’. The attention of the Court has been drawn to the decision of the Karnataka High Court in CIT v. Motorola India Electronics Pvt. Ltd. (2014) 46 Taxmann.com 167 (Kar.) which held that there was a direct nexus between the interest received from the FDRs created by a similarly placed Assessee from the amounts borrowed by it. The High Court approved the order of the ITAT in that case which held that the entire profits of the business of the undertaking should be taken into consideration while computi…

ACIT, Gurgaon vs. M/S. Qh Talbros Ltd., Gurgaon

In the result, both the appeals filed by the Revenue are dismissed

ITA 1321/DEL/2012[2007-08]Status: DisposedITAT Delhi04 Nov 2015AY 2007-08

Bench: Shri Inturi Rama Rao & Ms. Suchitra Kambleassessment Year: 2007-08 Acit, Circle-2, Vs. M/S Qh Talbros Ltd., Plot No. 400, Gurgaon Udyog Vihar, Phase-Iii, Gurgaon (Pan: Aaaco2191D) (Appellant) (Respondent) & Assessment Year: 2008-09 Dcit, Circle-2, Vs. M/S Qh Talbros Ltd., Plot No. 400, Gurgaon Udyog Vihar, Phase-Iii, Gurgaon (Pan: Aaaco2191D) (Appellant) (Respondent) Appellant By :Smt. Anjula Jain, Sr. Dr Respondent By : Sh. V.K. Aggarwal, Ar Date Of Hearing: 29.10.2015 Date Of Pronouncement: 04.11.2015 Order Per Inturi Rama Rao, A.M.: The Present Appeals Filed By The Revenue Are Directed Against The Orders Of Cit(A), Faridabad, Dated 27.12.2011 & 20.12.2012 Passed For The Assessment Years 2007-08 & 2008-09 Respectively. The Revenue Raised The Following Grounds Of Appeal In Ita No. 1321/Del/2012:

For Appellant: Smt. Anjula Jain, Sr. DRFor Respondent: Sh. V.K. Aggarwal, AR
Section 10BSection 115JSection 154Section 36(1)(iii)

…at would arise is whether the interest on the FDRs could form part of the ‘profits of the business of the undertaking’. The attention of the Court has been drawn to the decision of the Karnataka High Court in CIT v. Motorola India Electronics Pvt. Ltd. (2014) 46 Taxmann.com 167 (Kar.) which held that there was a direct nexus between the interest received from the FDRs created by a similarly placed Assessee from the amounts borrowed by it. The High Court approved the order of the ITAT in that case which held that the entire profits of the business of the undertaking should be taken into consideration while computi…

TAX – 21 vs. Universal Precision Screws

The appeal is dismissed

ITA/392/2015HC Delhi06 Oct 2015
Section 10ASection 10B

…uld arise is whether the interest on the FDRs could form part of the ‘profits of the business of the undertaking’. The attention of the Court has been drawn to the decision of the Karnataka High Court in CIT v. Motorola India Electronics Pvt. Ltd. (2014) 46 Taxmann.com 167 (Kar.) which held that there was a direct nexus between the interest received from the FDRs created by a similarly placed Assessee from the amounts borrowed by it. The High Court approved the order of the ITAT in that case which held that the entire profits of the business of the undertaking should be taken into consideration while…