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    Technical misdescription of deduction provision cannot defeat genuine donation relief where payment to an approved institution is otherwise eligible.
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      Government salary grant received by a charitable trust under a...

      Tied-up government grant excluded from accumulation base for charitable trust exemption under section 11(1)(a)

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      Income TaxJune 6, 2026Case LawsAT
      Government salary grant received by a charitable trust under a binding condition for use only in salary payments was treated as a tied-up receipt and excluded from the income base for accumulation under section 11(1)(a). The Tribunal held that accumulation is available only in respect of income held under trust that is at the assessee's disposal and capable of being applied or set apart at its discretion; here, the trust acted merely as a conduit without dominion or beneficial control. The Bombay HC ruling in CIT v. Gem & Jewellery Export Promotion Council was distinguished because it concerned characterisation of grants as income, not their inclusion in the accumulation base.

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      ActsIncome Tax