Exemption u/s 11 denied - grants received by the assessee - Such...

Exemption u/s 11 denied - grants received by the assessee - Such grants were not the donations or voluntary contribution u/s 12 - The grants received by the assessee for specific infrastructure projects which has also been utilized for those specific purposes only and since the assessee was not authorized to use the said grants for any other purpose and further that the unused funds have been returned to the Government, therefore, the aforesaid grants, in our view, do not constitute the income of the assessee. - AT