Taxability of Dharmarth receipts collected by Assessee Company

The only dispute before us is as to whether the receipts were, in fact, Dharmarth receipts. The assessee’s stand in this regard is that it was collecting Dharmarth in GRs and gate passes, as part of charity; that this Dharmarth collected every month was being passed on to a charitable trust; and that the receipt was neither shown as income, nor as expenditure. This stand of the assessee is entirely in line with its stand for the earlier years, right from assessment year 2001-02 to assessment year 2008-09. For all these years, in scrutiny assessments framed

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