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    <title>2014 (11) TMI 100 - ITAT DELHI</title>
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    <description>Receipts collected under the assessee&#039;s statutory powers were held to remain part of its own funds, because the office memorandum did not vest those amounts in the State Government or create a prior title in another entity. The direction merely required the sums to be credited to a designated account and spent for specified development purposes, so the arrangement amounted to application of income rather than diversion by overriding title. The claim that the infrastructure fund contributions were outside taxable income therefore failed. A separate unsigned document was also rejected, since it was unauthenticated and could not be admitted without compliance with the procedure for additional evidence.</description>
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      <link>https://www.taxtmi.com/caselaws?id=252783</link>
      <description>Receipts collected under the assessee&#039;s statutory powers were held to remain part of its own funds, because the office memorandum did not vest those amounts in the State Government or create a prior title in another entity. The direction merely required the sums to be credited to a designated account and spent for specified development purposes, so the arrangement amounted to application of income rather than diversion by overriding title. The claim that the infrastructure fund contributions were outside taxable income therefore failed. A separate unsigned document was also rejected, since it was unauthenticated and could not be admitted without compliance with the procedure for additional evidence.</description>
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