9911796707
TMI Blog2024 (9) TMI 635X X X X Extracts X X X X X X X X Extracts X X X X ..... e in the subsequent period to the extent of expenditure incurred. Assessee has produced detailed working on recognition of income and Unspent Grant for AY 2021-22 and AY 2022-23 to prove that the Unspent grant for AY 2021-22 was recognized as income in AY 2022-23 as against actual receipt of Rs. 2,96,57,598/-, an income of Rs. 3,76,29,175/- was offered to tax in AY 2022-23, which can be corroborated from Annexure A produced. Considering the fact that the Unspent Grant income has been offered to tax in the subsequent year i.e. AY 2022-23, we find no reason to make an addition at the hands of the Assessee in the year under consideration. Accordingly, the subject addition made by the AO is hereby deleted. Appeal filed by the Assessee is allowe ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... modify the aforesaid grounds of appeal either at or before the hearing the appeal. 3. Brief facts of the case are that, the assessee filed its return for Assessment Year 2021-22 declaring total income at NIL. The return was processed u/s 143(1) of the Income Tax Act, 1961,( Act for short) determining total income at Rs. 69,84,169/- on account of difference in actual FCRA received by the assessee and the income declared by the assessee in its return of income. Aggrieved by the assessment order, the assessee filed rectification application and an order u/s 154 of the Act came to be passed on 12/01/2023 by determining the total income of the assessee t Rs. 69,84,169/-. Aggrieved by order passed u/s 154 of the Act the assessee preferred an app ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... zed as a liability. However, on perusal of ITR it is seen that during the year appellant reflected only Rs. 2,08,07,170/- as income receipts out of the FCRA received of Rs. 2,77,91,339/-. It is to be noted that appellant did not file Balance Sheet Profit Loss account along with the return of income filed during the year. This is also fact that appellant has not refunded unspent FCRA receipts. There is no doubt that the appellant has treated funds received through FCRA as revenue receipts. If the object for which appellant received did not completed during the year and the amount was carry forwarded and offered as revenue receipts in the next year but appellant failed to prove with the documentary evidences and therefore, the explanation giv ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ee. 8. We have heard both the parties and perused the material available on record. The Assessee has been following Accrual basis of accounting, the Assessee recognized an income of Rs. 2,08,07,170/- for AY 2021-22 and reported the said income in Serial No. B(ii) of Schedule VC and carried forward the liability as Unspent Grant for INR 1,04,99.998/- in the Balance Sheet under Note D-Other Current Liabilities which is recognized as Income in the subsequent period to the extent of expenditure incurred. The Assessee has produced detailed working on recognition of income and Unspent Grant for AY 2021-22 and AY 2022-23 to prove that the Unspent grant for Ay 2021-22 was recognized as income in AY 2022-23 as against actual receipt of Rs. 2,96,57,5 ..... X X X X Extracts X X X X X X X X Extracts X X X X
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