1998 (9) TMI 38

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....vernment to an undertaking owned by it, is according to the Revenue, reimbursement of revenue expenditure and is therefore to be treated as taxable income for the year, while according to the corporation which received the amount, it is a capital receipt earmarked for a specific purpose and shown in the balance-sheet as "Fairs and Exhibition Fund". During the financial year 1973-74, the Governmen....

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....ts were shown as amounts earmarked for setting up a permanent exhibition wing. Though the Income-tax Officer and the Commissioner held that this amount is income and taxable as such, the Tribunal held after consideration of all the three Government orders together and the position prevailing as at the end of the financial year, that the amount was received as capital funds, we are in agreement wi....