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Judgment
ORDER
This assessee’s appeal for Assessment Year 2017-18, arises against the Addl / JCIT(A)-1 Coimbatore’s DIN & Order No. ITBA/AP L/S/250/2023-24/1057124347(1) dated 17.10.2023, in proceedings u/s 143(1) the Income Tax Act, 1961 (in short “the Act”).
Heard both the parties at length. Case file perused.
Coming to the Assessee’s sole substantive ground raised herein, it emerges during the course of hearing that both the learned lower authorities have assessed it for a sum of Rs. 19.20 lacs as forming part of its taxable income; in the CPC’s “processing” u/s. 143(1) of the Act as upheld in the lower appellate discussion.
That being the case, the revenue could hardl y dispute going by the necessary grant approval coming from the Government of NCT of Delhi dated 15.6.2016 (Annexure A-3); that it came with a specific condition representing “Targeted Intervention Project” for the welfare of female sex workers. This clinching fact has gone un-rebutted from the Revenue side. This tribunal is accordingl y of the considered view that both the learned lower authorities could have considered the foregoing grant in aid received from the Govt. of NCT of Delhi as assessee’s taxable income. The impugned addition of Rs. 19.20 lacs stands deleted accordingl y.
In the result, the appeal is allowed.