- (1.) This income tax appeal by the assessee-appellant relates to the assessment year 1998-99.
(2.) The assessee-appellant is an exporter of carpets. He was under an obligation to invest some money in fixed deposit with the bank in order to avail credit facility for export. On this fixed deposit he earned interest. He claimed deduction of 90% of the said interest under explanation (baa) to sub-section (4C) of Section 80HHC of the Income Tax Act (in short "the Act"). It was disallowed by the assessing officer. The appeal of the assessee-appellant before the Commissioner Income Tax (Appeals) failed and so was his further appeal to the Income Tax Appellate Tribunal, Agra.
(3.) The present appeal has been preferred against the order of the Income Tax Appellate Tribunal dated 28.12.2006 on the short substantial question of law whether the interest of Rs.10,32,523 earned by the assessee-appellant on fixed deposit receipts pledged with the bank for availing credit facility for the purposes of export is income from business or it would be income from other sources, liable to deduction in terms of explanation (baa) after sub-section (4C) of Section 80HHC of the Act while computing his taxable income under the head "profits and gains of business and profession".;