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2018 (12) TMI 320 - AT - Income TaxExemption u/s 11(1)(d) - grant received - proof of charitable activities - Held that:- Grants were received by the appellant from Government of India for specific purpose. As per the notifications issued by Government of India it has been specifically laid down that these Grants are for specific purposes and only the interest earned on the same it to be used/applied for the purposes of the objects of appellant institute. The amounts received in Grants have to be held as deposits and only interest earned therein is to be applied towards objects of institute. The Grants as such cannot be applied or utilized. The appellant has accounted the interest earned on the Grants as its income. Once a grant is received from Government Agency with certain conditions and stipulations provided therein and it is also specified for which purposes such grant has to be utilized, then that grant cannot be the income of the assessee. If such grant is not utilized for specific purpose, then automatically it has to be refunded back again to the Government Agency. The grants so received by the appellant from the Government to tie utilized for specific purpose cannot be held to be income of the appellant. - decided in favour of assessee.
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