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    <title>2011 (12) TMI 375 - ITAT, Delhi</title>
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    <description>A development authority&#039;s receipts credited to an infrastructure fund were held not to be diverted by overriding title. The statutory framework showed that the authority collected fees and charges in its own right, maintained its own fund, and applied those receipts to its functions. The Government memorandum only required a separate account and regulated the spending of a fixed portion for infrastructure purposes; it did not divest ownership in the receipts at source. The obligation was therefore one of application of income after receipt, not diversion before receipt, and the receipts remained taxable in the authority&#039;s hands.</description>
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      <link>https://www.taxtmi.com/caselaws?id=212581</link>
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