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2021 (6) TMI 212 - ITAT MUMBAIAccrual of income - interest earning from fixed deposits made from grant in aid - CIT-A deleted the addition - HELD THAT:- The Government directive which has been relied upon by him is duly applicable for the current assessment year. As per the said direction the interest on unutilised grant has to be treated a part of the grant itself. Hence, it cannot be subject to tax by the Revenue. In this view of the matter, there is change in circumstances and the ITAT order relied upon by the Assessing Officer is not at all applicable. As at that time there was no direction for such treatment. Further submission and case laws referred by the learned Counsel of the assessee is duly applicable on the facts and circumstances of the case. Nothing was brought before us referring the cogent finding of learned CIT(A). Hence, we uphold the order of learned CIT(A). Unutilized revenue grant - AO treated the entire Revenue grant received as the income of the appellant in the year of receipt and accordingly, made an addition - CIT-A deleted the addition - HELD THAT:- We find that policy of accounting for grant on receipt in current liability has been accepted by the Revenue in the earlier year. The utilisation of the same is duly accounted for. The unutilised grant is accepted in liability. Having accepted the above policy earlier the Assessing Officer is taking a different view in the current year. We agree with learned CIT(A) that on the principle of consistency the Assessing Officer’s action is not justified without pointing out why contrary view from earlier year is being taken. Hence, we uphold the order of learned CIT(A). - Revenue appeal dismissed.
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