Assessee-trust was registered under section 12AA and was constituted for construction of infrastructure on behalf of Government of West Bengal. During relevant assessment year, assessee received specific grants from Government through urban development department for implementation of various infrastructure projects. Assessee showed said funds in balance sheet as part of corpus of trust and did not offer same for tax as income. Assessing Officer opined that only voluntary contributions made with a specific direction that contribution shall form part of corpus of trust could be treated as corpus donation. He, thus, added back government grant in income of assessee on ground that no express direction was given from Government that funds would form part of corpus and basic nature of grant was that it was meant for application. Since grants were given to assessee for specific infrastructure projects and did not belong to assessee and furthermore assessee was not authorized to use said grants for any other purpose and unutilized funds were returned to Government, said grants were not voluntary contributions and would not constitute income of assessee. Thus, impugned additions were to be deleted. (AY. 2015-16)