Grant-in-aid as Capital Receipt under Income Tax Act: ITAT overlooks Section 11 context; no profit generation potential.

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....Exemption u/s 11 - whether the grant-in-aid received by the assessee was capital receipt or revenue receipt? - Even by way of amendment to Section 2(24) (xviii), exemption is available to the institutions like the assessee, as noticed above. - ITAT has definitely not considered the matter in the above noted context. The fact that the assessee received only one time grant with a specific purpose which nowhere suggested scope of profit generation or revenue for the assessee, the amount received by the assessee by way of grant-in-aid thus could not be termed to be revenue receipt. - HC....