Surplus/Savings arising on prepayment of deferred sales tax not taxable u/s (iv)

Brief of the case:

The ITAT Mumbai in the above cited case held that the surplus/savings  arising on prepayment of deferred cannot be taxed u/s 28(iv) as by making prepayment of a future liabity  at present value no monetary benefit arises to assessee  as the savings it made by prepayment would get set off against the interest it loses by making prepayment.

Facts of the case:

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