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    <title>2022 (9) TMI 1186 - ITAT DELHI</title>
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    <description>Grants received for specified overseas fairs and buyer-seller meets, subject to strict conditions on separate accounting, use only for the sanctioned purpose, audit, and refund of unspent amounts, were treated as tied-up grants rather than voluntary contributions. Because the funds were not freely available for general application, they did not constitute the assessee&#039;s income or corpus for sections 11 and 12. The related foreign expenditure was also not disallowed merely for lack of prior approval under section 11(1)(c) on these facts. The grant receipts were therefore held non-taxable as income, and the Assessing Officer&#039;s disallowance was deleted.</description>
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      <link>https://www.taxtmi.com/caselaws?id=428241</link>
      <description>Grants received for specified overseas fairs and buyer-seller meets, subject to strict conditions on separate accounting, use only for the sanctioned purpose, audit, and refund of unspent amounts, were treated as tied-up grants rather than voluntary contributions. Because the funds were not freely available for general application, they did not constitute the assessee&#039;s income or corpus for sections 11 and 12. The related foreign expenditure was also not disallowed merely for lack of prior approval under section 11(1)(c) on these facts. The grant receipts were therefore held non-taxable as income, and the Assessing Officer&#039;s disallowance was deleted.</description>
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