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    <title>2023 (10) TMI 397 - ITAT DELHI</title>
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    <description>Receipts collected by the council from sugar mills for a statutorily earmarked developmental purpose were held not to constitute income under section 2(24) because the funds were required to be used for road construction and other developmental work, with unspent amounts carried forward for the same object. As the amounts were neither diverted, distributed as profit, nor applied to any non-statutory purpose, their character did not change into taxable income. The council&#039;s status as a local authority was not determinative of the tax result. The addition was therefore unsustainable, and the first appellate authority&#039;s finding was upheld in favour of the assessee.</description>
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    <pubDate>Wed, 27 Sep 2023 00:00:00 +0530</pubDate>
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      <link>https://www.taxtmi.com/caselaws?id=444174</link>
      <description>Receipts collected by the council from sugar mills for a statutorily earmarked developmental purpose were held not to constitute income under section 2(24) because the funds were required to be used for road construction and other developmental work, with unspent amounts carried forward for the same object. As the amounts were neither diverted, distributed as profit, nor applied to any non-statutory purpose, their character did not change into taxable income. The council&#039;s status as a local authority was not determinative of the tax result. The addition was therefore unsustainable, and the first appellate authority&#039;s finding was upheld in favour of the assessee.</description>
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