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    <title>2015 (1) TMI 1236 - ITAT LUCKNOW</title>
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    <description>Receipts described as grants and commission-based contributions received from the Government and sugar factories were examined for possible inclusion in income under section 2(24) of the Income-tax Act, 1961. The Tribunal noted that the amounts were earmarked for specific development purposes, including road construction and assigned works, and that the assessee had no independent right to use them for any other purpose. It observed that grants or contributions tied to a specific object and not arising from normal business activity may not necessarily be income. As the plea was raised for the first time before the Tribunal, the claim required fresh factual and legal examination at the assessment stage, and the matter was restored to the Assessing Officer.</description>
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