ACIT, CENTRAL CIRCLE, KARNAL vs. MAHARISHI MARKANDESHWAR TRUST, AMBALA CITY

ITA 6850/DEL/2025Status: DisposedITAT Delhi23 September 2026AY 2020-214 pages
AI SummaryDismissed

What were the facts?

The Revenue appealed against the CIT(A)'s order which treated a Development Fund of Rs. 13,32,42,321/- as corpus donation. The assessee, a charitable trust running educational institutions, had collected this fund from students for capital expenditure.

What did the Tribunal hold?

The Tribunal followed its own previous order in the assessee's own case, which held that development fees collected for specific capital expenditure should be treated as corpus receipts under Section 11(1)(d). Therefore, the CIT(A)'s decision to treat the fund as corpus was upheld.

What were the issues?

Whether the Development Fund collected by the assessee constitutes a corpus donation or a revenue receipt, and if it qualifies for exemption under Section 11(1)(d).

Which sections of the Income-tax Act were involved?

Section 11(1)(d)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, DELHI

Before: SHRI M BALAGANESH & SHRI SUDHIR KUMAR

For Respondent: Shri Dhruv Goel, CA

PER SHRI SUDHIR KUMAR, JM :

This appeal by the Revenue is directed against the orders of the Commissioner of Income-tax (Appeals)-3, Gurgaon [hereinafter referred to as “Ld.CIT(A)”] vide order dated 04-07-2023 relevant to assessment year 2020-21. 2. The Revenue has raised the following ground in appeal as under:

1.

Whether the CIT(A) has erred in law and on facts in holding that the amount of Rs. 13,32,42,321/- received towards the ‘Devel

The order continues below.

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