(1.) SRI M.V. Seshachala, learned Counsel appeared on behalf of the appellants.
(2.) HEARD on admission. Records perused.
(3.) THE appellants had approached the Tribunal challenging the order passed by the Commissioner of Income Tax (Appeals) in deleting the interest income brought to tax amounting to Rs. 22,55,82,940. It is not in dispute that the assessee is a nodal agency and is not carrying on any business of its own. It is only an implementing agency. The money received from the bank and interest accrued thereon is parked with the assessee for implementation of the scheme entrusted to it. It is not carrying on business activities of its own and every rupee received by it is accounted for.