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2021 (8) TMI 291 - AT - Income TaxExemption u/s 11 - registration u/s 12A denied - accounts of the assessee were defective as the assessee failed to incorporate receipts from “ Government grant account” - expenditure against specified grants - HELD THAT:- CIT held that no amount of grant has been received by the Assessee and grant is still to be received as are certain enquiries pending against the Assessee the sanction of the grant has lot of conditions. This also evident from the letter shown by the ld AR. There is no certainty of the grant to be received by the Assessee in view of the pending enquiries against the Assessee which is also takes report of Controller and Auditor General of India. He also noted that legal income raised by the central account office and the branches of the Assessee has been correctly accounted for by the Assessee. He further held that the Assessee has incurred expenditure and therefore, in absence of any grant received by the Assessee during the year the grant income could not have been accounted for as it neither accrued nor received. This fact is shown by the letter of the Govt. of India as well as the utilization certificate issues by the Chartered Accountant - we do not find any infirmity in the order of the LD CIT (A) in holding that the disallowance made in the hands of the Assessee of the expenditure is not sustainable. - Decided against revenue.
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