Interest received by bank post liquidation can’t be taxed if same was required to be transferred to DICGCI

INCOME TAX : Where assessee, a co-operative bank under liquidation, had borrowed money from DICGCI (subsidiary of RBI) for making payment to depositors and as per understanding with DICGCI, assessee was liable to make payment to DICGCI, interest income received by assessee-bank post liquidation was diverted at source by overriding title for payment of liabilities of DICGCI and same would not be taxable as income in hands of assessee

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