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2016 (11) TMI 526 - AT - Income TaxAddition on account of grant received under Sampoorna Gramin Swarojgar Yogna (SGSY) from Government - whether the assesses started its commercial activities much before the receipt of the aforesaid grant, hence the same ought to be treated as revenue receipt as per Explanation 10 of section 43 ?- Held that:- Respectfully following the decision of Hon. Punjab & Haryana High Court in the case of CIT vs. The Punjab State E-Governance Society (2011 (4) TMI 1332 - PUNJAB & HARYANA HIGH COURT ) also going through the detailed finding of ld. CIT(A) and in the given facts and circumstances of the case we are of the view that grant received under SGSY Scheme from Government of Gujarat cannot be treated as revenue receipt of the assessee as it was received specifically towards attainment of objectives enumerated in the MOU between the appellant, District Rural Development Agency, Nadiad (DRDA) and Commissioner, Rural Development, Government of Gujarat, Gandhinagar and assessee had no authority to use this grant towards its normal business activities. Therefore, we find no reason to interfere with the order of ld. CIT(A). - Decided against revenue
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