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    <title>2019 (4) TMI 548 - ITAT CHANDIGARH</title>
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    <description>Amounts collected by a society merely as a statutory conduit for remittance to the State, with no beneficial ownership and no real profit or gain accruing to it, do not constitute taxable income under the Income-tax Act. The Tribunal noted that the collections were made while performing a statutory function linked to the VAT regime and that the amount ultimately belonged to the State Government, so the Revenue&#039;s additions could not stand. Non-registration under section 12AA was irrelevant because the core question was whether any real income had arisen, and section 40(a)(iib) did not alter the position that the receipts were not income at all.</description>
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      <description>Amounts collected by a society merely as a statutory conduit for remittance to the State, with no beneficial ownership and no real profit or gain accruing to it, do not constitute taxable income under the Income-tax Act. The Tribunal noted that the collections were made while performing a statutory function linked to the VAT regime and that the amount ultimately belonged to the State Government, so the Revenue&#039;s additions could not stand. Non-registration under section 12AA was irrelevant because the core question was whether any real income had arisen, and section 40(a)(iib) did not alter the position that the receipts were not income at all.</description>
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