Tribunal held that the Object of  promoting growth of  Automobile Industry In India and also to improve and protect environment-Entitled to exemption. Followed, Society of Indian Automobile Manufacturers v. ITO (E) (I. T. A. No. 4837/Delhi/2012 dated June 6, 2016). Tribunal also, that the assessee while drawing up the excess of expenditure carried forward the amounts and the balance as excess income over expenditure. In the schedule to the balance-sheet the amount of Rs. 90 lakhs was transferred to corpus funds with the narration “transfer from income and expenditure account, i. e., for Rs. 90 lakhs”. Similarly, amounts were transferred to different funds. The assessee had very clearly pointed out that all these amounts which were transferred to funds were not to be considered as application of income and accordingly, the income had been computed in the hands of the assessee. There was no merit in the exercise undertaken by the Assessing Officer, which had been confirmed by the Commissioner (Appeals). The Assessing Officer was directed to delete the addition made in the hands of the assessee. As regards Foreign Contribution the Tribunal held that  section 11(1) of the Foreign Contribution (Regulation) Act of 2010 very clearly provides that no person shall accept foreign contributions unless such person has obtained a certificate from the Central Government. Further, sub-section (2) provides that foreign contribution is to be utilised for specific purpose only after obtaining appropriate permission of the Central Government. Thus, the assessee did not have the authority to utilise the sum received by it as foreign contribution though it was credited to its bank account. Similarly, the bank interest earned on such deposits was in the form of foreign contribution and specific approval for utilisation thereof had to be given by the Central Government. The characterisation of a receipt could taxable only at the time of appropriation and not at the time of receipt which at best was advance received, which did not bear any particular characterisation for the purpose of treating it as income. The foreign grant as pending approval could not be included as income of the assessee. Relied on CIT v. Om Prakash Khaitan(201) 376 ITR 390 (Delhi)(HC). As no addition was confirmed levy of penalty was deleted for the AY. 2009-10. (AY. 2009-10, 2010-11)