In the result all three appeals of the Assessee are partly allowed

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudhary

capital nature, could not be treated as an income earned during the year by the appellant. Therefore, the sum of Rs. 12.97 Crores could not be treated to the income of the appellant authority, much less taxed in its hands. 8.3 The learned CIT(A) did not agree with the submissions of the assessee. He pointed out that