JUDGMENT : M.R. Shah, J. 1. Feeling aggrieved and dissatisfied with the impugned judgment and order passed by the learned Income Tax Appellate Tribunal, Ahmedabad 'D' Bench, Ahmedabad (hereinafter referred to as "the learned tribunal") in ITA No. 981/Ahd/2011 for the Assessment Year 1991-92, revenue has preferred the present Tax Appeal to consider the following substantial questions of law; (a) Whether the appellate tribunal is right in law and on facts in directing not to exclude the finance charges for the purpose of computation of deduction under Section 80HHC of the Act? (b) Whether the appellate tribunal is right in law and on facts in holding that interest received for providing credit should not be deducted for the purpose of computation of deduction under Section 80HHC of the Act?" 2. The issue is with respect to the interest charged by he assessee on delayed payment of sale consideration by the purchaser (for a period of 90 days). The Assessing Officer held that the interest charged by the assessee for a period of 90 days on the delayed payment of sale consideration has no nexus with the business activities, and therefore, has no nexus with the profit of the assessee - Company, and therefore, the same is required to be included and/or considered as income on other sources and not as business income. The learned CIT(A) allowed the same and the learned tribunal has confirmed the same relying upon the decision of the Division Bench of this Court in the case of Commissioner of Income Tax v. Nirma Ltd. reported in 2014 (367) ITR 12. Feeling aggrieved and dissatisfied with the impugned judgment and order passed by the learned tribunal in directing not to exclude the finance changes for a credit period of 90 days under Section 80HHC of the Act, revenue has preferred the present Appeal with the above stated questions. 3. Ms. Mauna Bhatt, learned advocate appearing on behalf of the revenue has submitted that the learned tribunal has not properly appreciated the fact that the interest charged by the assessee for the period of 90 days on delayed payment of sale consideration by the purchaser has no nexus with the business activities. 3. Ms. Mauna Bhatt, learned advocate appearing on behalf of the revenue has submitted that the learned tribunal has not properly appreciated the fact that the interest charged by the assessee for the period of 90 days on delayed payment of sale consideration by the purchaser has no nexus with the business activities. It is submitted that the learned tribunal has not properly appreciated the fact that as such the assessee was not dealing in the money lending business and/or finance business, and therefore, earning the interest on 90 days on payment of sale consideration by the purchaser cannot be said to have any nexus with the business activities. The same is required to be treated and considered as income from other sources. It is submitted that in support of her above submissions, she has heavily relied upon the decision in the case of Commissioner of Income-tax, Thiruvananthapuram v. K. Ravindranathan Nair reported in 2007 (295) ITR 228 . Making the above submissions and relying upon the above decision of the Hon'ble Supreme Court, it is requested to admit the present Appeal. 4. Heard the learned Counsel appearing on behalf of he revenue at length. As observed hereinabove, the question, which is posed for the consideration of this Court is, whether the interest charged/earned by the assessee from its purchasers for the period of 90 days on the delayed payment of sale consideration can be said to be income from other sources and/or it can be said to have nexus with its business activities for which the assessee is allowable the deduction under Section 80HHC of the Income Tax Act. As such, identical question came to be considered by the Division Bench of this Court in the case of Nirma Industries Ltd. v. Deputy Commissioner of Income-tax reported in [2006] 283 ITR 402 (Guj.). In the case before the Division Bench the question was with respect to interest received on late payment of sale consideration and the question was whether the said amount can be said to be arrived from business or not. It is specifically observed and held by the Division Bench of this Court that such amount of interest received on late payment of sale consideration can be said to have been derived from business and the same is included in profits for the purpose of Section 80-I of the Income Tax Act, 1961. It is specifically observed and held by the Division Bench of this Court that such amount of interest received on late payment of sale consideration can be said to have been derived from business and the same is included in profits for the purpose of Section 80-I of the Income Tax Act, 1961. The said decision has been subsequently followed by the Division Bench of this Court in the case of Commissioner of Income Tax v. Nirma Ltd. reported in 2014 (367) ITR 12, the decision which has been relied upon by the learned tribunal while passing the impugned judgment and order. The submissions on behalf of the revenue that as in the present case as the special provision has been made by the assessee with respect to the interest charged/earned for a period of 90 days from the purchaser on delayed payment of sale consideration, and therefore, the same cannot be stated to have any nexus with the business is concerned, it is required to be noted that merely because some special provision is made by the assessee, it cannot be said that interest earned on late payment of sale consideration would be the amount derived from business. 4.1 Now so far the reliance placed upon the decision of the Hon'ble Supreme Court in the case of Ravindranathan Nair (Supra) is concerned on considering the facts of the case before the Hon'ble Supreme Court, we are of the opinion that the said decision would not be applicable to the facts of the case on hand. In the case before the Hon'ble Supreme Court the assessee claimed the deduction with respect to the charges paid for purchasing material of the purchasers. To that it was held that the same cannot be permitted to be deducted and the same cannot be said to be as income earned by business. As observed hereinabove, the issue is directly covered by the decision of the Division Bench of this Court in the case of Nirma Industries (Supra). We are in complete agreement with the view that the interest earned/charged by the assessee on the delayed payment of sale consideration (for 90 days) is not required to be excluded for the purpose of computation of deduction under Section 80HHC of the Act. No substantial question of law arises in the present Tax Appeal. Hence, the present Appeal deserves to be dismissed.