Amounts transferred to TDF and WDF by the assessee acting as nodal or implementing agency as per the schemes framed by the Government of India for promotion of investments in agriculture and rural development stood diverted at source itself and did not belong to the assessee and, therefore, the said amounts cannot be brought to tax in the hands of the assessee. (AY.2010-11)
Dy. CIT v. National Bank for Agriculture & Rural Development [2023] 221 TTJ 25 / 221 DTR 369 (Mum)(Trib.)
S. 4 : Charge of income-tax-Diversion by overriding title -Transfer of interest receipts to tribal development fund (TDF) and watershed development fund (WDF) per scheme devised by Government of India for promotion of investments in agriculture and rural development- Not chargeable to tax. [S. 145]