Addition untenable as decentralized grants routed through assessee is not actually accrued or arisen

DCIT Vs Tourism Corporation of Gujarat Ltd (ITAT Ahmedabad) ITAT Ahmedabad held that taxation must be based on income that has actually accrued or arisen. Thus, addition towards decentralized grants merely routed assessee and simply transferred to other government agencies as per GOG’s directions is unsustainable. Facts- The assessee, M/s Tourism Corporation of Gujarat Ltd. (TCGL), engaged in the promotion and development of tourism in Gujarat. During the course of assessment proceedings, the AO observed that the statutory auditors highlighted that the company consistently recognizes 15% of ...