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TMI Blog2017 (6) TMI 830X X X X Extracts X X X X X X X X Extracts X X X X ..... of assessee as income for the respective assessment years. Even where the assessee had shown the said amounts in the Receipts and Expenditure Account but the same cannot be held to be income of the assessee as no part of the said grants could be utilized by the assessee for any other purpose other than specific purpose, for which the same was granted. Accordingly, we direct the Assessing Officer to delete the addition - Decided in favour of assessee. - ITA Nos. 505 & 506/PUN/2014 - - - Dated:- 7-6-2017 - Ms. Sushma Chowla, JM And Shri Anil Chaturvedi, AM Appellant by : Shri M.K Kulkarni Revenue by : Shri A.N Honawar ORDER Per Sushma Chowla, JM Both the appeals filed by the assessee are against consolidated order of ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... n such circumstances income was not taxable in the hands of the Trust as has been confirmed by Ld. CIT(A). The addition confirmed by Ld. CIT(A) be quashed. 3) On the facts and circumstances of the case and in law the levy of interest u/s 234A, 234B and 234C is not justified. The levy of interest be quashed. 4) The appellant craves/leave to add, amend or alter any of the above grounds of appeal. 4. The learned Authorized Representative for the assessee pointed out that the assessee had received grant-in-aid from the Government of India for specific purpose and the surplus, if any, on account of corpus donations was to be utilized for such purpose only. Further, the surplus arising therefrom was to be carried forward to the subsequen ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... nt was made towards corpus of the trust. 8. The assessee is in appeal against the order of CIT(A). 9. We have heard the rival contentions and perused the record. In the facts of the present case, the assessee trust received funds from the Government of India as per sanction of the President of India under the scheme of Support to Training and Employment Programme for women STEP . The grant was made to the assessee for specific purposes which were mentioned in the communication sanctioning the grant. It was also mentioned in the said sanctioned letter that the surplus, if any, would be carried forward and would be utilized for the same purpose in the stipulated period thereafter. The assessee has placed on record various sanctioned le ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... t Society in ITA No.210 of 2011, judgment dated 19.10.2011 and Chandigarh Bench of Tribunal in Chief Administrator, Haryana Rural Development Authority Vs. DCIT (2014) 162 TTJ 749 (Chd). 10. Applying the said principle, where the assessee was constituted by the Government of India for specific purpose of carrying the activities for the empowerment of women and the grants advances disbursed by the Government to the assessee cannot be held to be the income of assessee since the said grants were released for specific purpose in the field of empowerment of women and the surplus, if any, is not assessable in the hands of assessee as income for the respective assessment years. Even where the assessee had shown the said amounts in the Receipt ..... X X X X Extracts X X X X X X X X Extracts X X X X
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