true character

We have duly considered the rival contentions and the material on record. The crux of the matter is to determine the true character of the receipt in the hands of the assessee and not the utilization thereof. The utilization will not determine the nature of the receipt. The assessee may mis-utilise the funds but that will not either determine or change the character of the receipt. The foremost thing to be appreciated is that the assessee has taken Full Article