2017 (6) TMI 353

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....of unutilized revenue grant?" 2. We notice that in case of Tax Appeal No.1934 of 2009, Division Bench of this Court in a judgment dated 2.5.2011 in substantially similar factual background has made following observations:- "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 owned Corporation established for the purpose of upliftment of Safai Kamdars and certain members of Scheduled Caste involved in manual scavenging and other similar activities. During the year in question, the assessee receive....

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.... 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 Government Resolution dated 9th December 2000. Preamble to the Government resolution states that in the State there are 33,000 Safai Kamdars and 31,000 dependents of such Safai Kamdars. 7500 Safai Kamdars have been given alternate employme....