Tribunal held that ;where  three Governments coming together and doing business by themselves by constituting a society. Its main objects related to providing technical, advisory and consultancy services for small and medium scale industries across the State of Gujarat, besides for improving skills and knowledge of the personnel of the tool room. To achieve these objects, the promoters provided funds in the form of grants towards capital fund. Such contribution in the form of grants could not be considered as a payment directly or indirectly to meet any portion of the actual cost and, thus, did not fall within the ambit of Explanation 10 to section 43(1)(AY.2013-14 )