2014 (2) TMI 846

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....ibunal has substantially erred in law in deleting the disallowance of Rs.7,68,96,000/- made by the Assessing Officer and confirmed by the CIT(A)?" 2. The facts leading to the present Tax Appeal in a nutshell are as under: 2.1 The assessee, who has been incorporated by the Government of Gujarat, as a nodal agency to regulate blood transfusion in the State of Gujarat and who is managing the funds relating thereto by securing grants from the State Government and distributing the same to various Red Cross Branches in the State of Gujarat, filed the return of income for the Assessment Year 2009-10 declaring the total income as 'NIL'. The case of the assessee was processed under Section 143(1) of the Income Tax Act. It was selected for scru....

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....Income Tax Act, the assessee preferred appeal before the CIT(A) and the CIT(A) dismissed the appeal confirming the addition made by the Assessing Officer. 2.3 Being aggrieved and dissatisfied with the order passed by the CIT(A) confirming the addition made by the Assessing Officer, the assessee preferred appeal before the ITAT and by impugned judgment and order the ITAT has allowed the appeal and deleted the additions made by the Assessing Officer observing that Rs.7,68,96,000/-, which was received by the assessee by way of grant from the State Government, cannot be said to be an income. Being aggrieved and dissatisfied with the impugned judgment and order, the revenue has preferred the present Tax Appeal to consider the aforesaid propos....