Deduction U/s. 80IA not available on interest on FDR by a company engaged in providing infrastructure facilities

DCIT Vs. SMS Paryavaran (P) Ltd. (ITAT Delhi) The Hon’ble ITAT held that interest earned on FDR maintained with the bank for obtaining bank guarantee for performance of any business activity even if related to any govt infrastructure  project can’t override the basic structure of Sec 80IA which intends to provide deduction only in respect of activities directly related to the process of providing infrastructure facilities. Income cannot be said to be derived from an activity merely by reason of the fact that activity was performed to earn the said income in an indirect, incidental or remo...