The assessee an institution created by Himachal Pradesh Nursing Registration Council Act, 1977 received one time grant-in-aid from Government of India with a specific purpose of upgradation and strengthening of institutions. The Assessing Officer assessed the grant in aide as income and denied exemption u/s 12AA of the Act. Order of the Assessing Officer was affirmed by the Tribunal On appeal the Court held that the amount received by assessee could not be termed to be revenue receipt and the assessment order was set aside.  (AY. 2011-12)