Unutilized welfare trust receipts returned to companies are non-taxable windfalls, not revenue income under the Income Tax Act.

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....Taxability of receipts from the welfare trusts - the said receipt being the unutilized portions, received back from the welfare trusts by the assessee company would not partake the character of a revenue receipt constituting income and would merely have to be treated as a windfall or non-recurring receipt not liable to tax, though not exempted under specific provisions of the Act. - AT....