2011 (5) TMI 815

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....bunal is correct in deleting the additional by following the principles of res judicata?   C. Whether the Appellate Tribunal is right in law and on facts in reversing the order of the CIT(A) and thereby holding that as per the provisions of section 12(1) of the Act, those receipts under the head "Thakkar Bapa Rehabilitation Grant" shown at Rs.8.97 Crores shall be deemed to be the income as referred to u/s.11(1) of the Act?"   Though multiple questions are framed, the issue is one, namely, whether the assessee was entitled to claim benefit of section 11(1)(d) of the Income Tax Act,1961 with respect to Government grant of Rs.8.97 crores received during the assessment year in question.   The assessee is a Government own....

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....nder which such grant of Rs.8.89 crores was made available. The Tribunal was of the opinion that the amount was disbursed for specific purpose and to be utilized for the purpose for which it was made available. The Tribunal also noted that in previous years, stand of the assessee was accepted by the Revenue.   From the documents on record, we gather that the objects of the Corporation, inter alia, were to grant concessional loans and advances to Safai Kamdars and their dependents, to examine the problems of Safai Kamdars and try to find their solutions, to promote economic developmental activities for the benefits of Safai Kamdars, their family members and dependents, etc. Grant of Rs.8.97 was made available to the Corporation under....