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of ITAT held that a one-time life-membership fee received by the assessee-trust is a capital receipt apportioned over 40 years under a long-standing accounting practice accepted by revenue; thus the fee constitutes a timing difference rather than current revenue. Relying on the principle that where tax rates across years remain constant no addition is warranted, ITAT rejected revenue's attempt to treat the entire fee as taxable in the year of receipt. The Assessing Officer is directed to exclude the apportioned corpus sum from computation of application of income for charitable purposes and to ignore the said amount when determining exemption under section 11.
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