Assessee declared nil income in return and same was accepted by Assessing Officer. Principal Commissioner held that government grants were given with specific directions, with no scope of savings and could not be treated as voluntary in nature and passed the revision order on ground that said grant would not be eligible for purpose of accumulation at rate of 15 per cent and remanded matter to Assessing Officer. Held that since in earlier years, revenue had accepted same as income of assessee as being eligible for accumulation under section 11 same was also to be accepted in current year following doctrine of consistency. Order of Revision without calling the records and application of mind. Order of Revision is set aside. (AY. 2015-16)
Gujarat State Lion Conservation Society v. CIT (2022) 196 ITD 172 (Rajkot)(Trib.)
S. 263 : Commissioner-Revision of orders prejudicial to revenue-Government grants-Accumulation of income-Doctrine of consistency-Accumulation of 15%-Revision is not valid. [S. 11(1)(a), 12]