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2020 (11) TMI 17 - HC - Income TaxAdditions towards Capital Grants & Subsidies and Consumers' Contribution - appellant should transfer 15% of the total Grants/subsidies/consumer contribution received during the year as against 10% offered by the appellant - Capital grant being @ 15% of total grant - HELD THAT:- We have gone through the material on record pertaining to the submission of the assessee stating that the assessee has not received any grant during the year and the grants received originally from the Govt. of Gujarat were apportioned against the subsidiary companies appropriate basis. In F.Y.2007-08, the State Government vide various GRS decided to convert the grant given during the F.Y. 2005-06 to 2007-08 [2019 (9) TMI 376 - ITAT AHMEDABAD] for implementation of Jyoti Gram Yojna (JGY) into equity share capital. Total grants received during the aforesaid financial years were allocated among the four distribution companies for implementation of the aforesaid scheme of the State Government. We do not find any infirmity with the decision of the Ld. Therefore, the aforesaid grants received cannot be treated as income of the assessee company. Accordingly, this ground of the appeal is dismissed
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