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2023 (10) TMI 397 - ITAT DELHIDetermination of status of assessee - AO was of the view that assessee is not a local authority for the purpose of Section 10(20) - AO being dissatisfied about the status of the assessee as registered u/s 12AA thereafter being dissatisfied considered the status of assessee as of juridical person - All receipts, for purposes of developmental work were considered as income u/s 2(24) of the Act. Therefore, in the absence of evidence, the expenses claimed were disallowed - HELD THAT:- The bench is of considered view that the conclusion of ld. AO was erroneous as with regard to the nature of receipts. The same were commissions received from various sugar mills in the hands of assessee for specific purpose of being used in the developmental activity so Ld CIT(A) has rightly held them to be not falling in the category of income for purpose of Section 2(24) of the Act and that being the case the status of assessee being local authority or otherwise was not of consequence. The grounds raised by the Revenue have no substance and the appeal of the Revenue is dismissed.
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