Judgment

Banerjee, J.-The core question, in these eight appeals, by the grant of special leave against the judgments of the High Courts of Orissa and Rajasthan, centres round the interpretation of Section 10(29) of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’).

2. Before however, proceeding further in these matters, it will be convenient to note that hearing of these appeals was taken up together by consent of the parties and these appeals being disposed of by a common judgment by reason of identity of the issue involved in these appeals.

3. The contextual facts in Appeal No. 3476 of 1993 depict that the Orissa State Warehousing Corporation being the assessee herein re­ceived a sum of Rs. 1,74,383/- as interest on fixed deposits for the assessment year 1983-84 and since during the relevant period the assessee has had to pay the total interest of Rs. 1,08,063/- to the banks, a sum of Rs. 66,320/- was added to the income of the assessee as the Income-tax Officer was of the view that question of resultant difference of income being Rs. 66,320/- cannot be said to be an ‘income exempt’ within the meaning of Section 10(29) of the Act.

4. The Commissioner of Income Tax (Appe