Revenue's Appeals Dismissed on "Pradhan Mantri Gram Sadak Yojana" Grants Assessability

The revenue's appeals against the CIT(A)'s decisions for assessment years 2005-06 and 2006-07 regarding the assessability of grants received under "Pradhan Mantri Gram Sadak Yojana" and interest on unutilized grants were dismissed. The CIT(A) rulings in favor of the assessee were upheld by the tribunal, emphasizing the specific purpose of the grants and the treatment of interest. Despite the revenue's contentions, the assessed income remained unaffected, leading to the dismissal of the appeals as having academic interest only.

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Issues:
- Appeal against two separate orders of CIT(A) for assessment years 2005-06 and 2006-07.
- Whether grants received under "Pradhan Mantri Gram Sadak Yojana" are assessable as income.
- Treatment of interest on unutilized grants as income.

Analysis:
1. Assessment Year 2005-06:
- The revenue appealed against the CIT(A)'s decision regarding grants received under "Pradhan Mantri Gram Sadak Yojana" not being assessable income.
- The CIT(A) noted the trust's registration under various acts and the nature of funds received under the scheme.
- The revenue argued against allowing the claim based on a Supreme Court judgment.
- The AR supported the CIT(A) with reference to a tribunal decision and subsequent confirmations by the High Court and Supreme Court.
- The CIT(A) decision was in favor of the assessee, citing the specific purpose of the grants and the treatment of interest on unutilized grants.
- The tribunal found the CIT(A)'s decision in line with previous judgments and dismissed the revenue's appeal.

2. Assessment Year 2006-07:
- The revenue contested the CIT(A)'s ruling on grants received under the same scheme and interest on unutilized grants.
- The bench highlighted that the assessed income remained nil even after additions due to the allowance under section 11 of the Income Tax Act.
- The bench considered the revenue's appeal as of academic interest only, as the assessed income remained unaffected.
- Consequently, the appeal was dismissed due to its academic nature.

3. Combined Result:
- Both appeals by the revenue were dismissed, affirming the decisions of the CIT(A) for both assessment years.
- The orders were pronounced in open court, concluding the proceedings.

This detailed analysis outlines the issues, arguments, and decisions made by the authorities in the legal judgment concerning the assessment years 2005-06 and 2006-07, specifically focusing on the treatment of grants received under the "Pradhan Mantri Gram Sadak Yojana" and interest on unutilized grants.

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