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Income Tax - Highlights / Catch Notes

Home Highlights January 2020 Year 2020 This

Exemption u/s 11 - corpus contribution of ₹ 150 Crores - ...


Section 11 Exemption: Rs. 150 Crore Corpus Contribution Deemed Specific Grant, Not Taxable Due to Capital Nature.

January 2, 2020

Case Laws     Income Tax     AT

Exemption u/s 11 - corpus contribution of ₹ 150 Crores - the mere fact that the assessee credited the receipts as corpus contribution, in our considered opinion, would not make much difference and would not alter the true nature of the stated receipts. The said funds / receipts, as stated earlier, were more in the nature of specific grants and represent liability for the assessee and liable to be refunded in case of non-utilization. Therefore, the same being capital in nature, could not be even otherwise brought to tax.

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