Interest on Unutilized Funds which could not be used in development of Port Terminal is Capital Receipt

M/s. Karanja Terminal & Logistics Pvt. Ltd. Vs DCIT (ITAT Mumbai) Interest income received by the assessee from the FDRs/ICDs made out of funds are inextricably linked to the development of port terminal and other infrastructure at Karanja Creek which is yet to be completed and commissioned. We would like to add that the these funds could not be used for the development work of the port due to late issuance of permissions/clearances by the Govt authorities and also due to some local issues. Therefore, in our considered view the interest income is a capital receipt and is not taxable at all...