SHAKUNTALA DEVI CHANDRA KUMAR MUNOT CHARITABLE TRUST,NEW DELHI vs. INCOME TAX OFFICER, CIVIC CENTRE

ITA 3430/DEL/2026Status: DisposedITAT Delhi03 August 2026AY 2021-229 pages
AI SummaryAllowed

What were the facts?

The assessee, a charitable trust, received corpus donations. The CPC treated these donations as taxable income due to the non-filing of Form 10B, denying exemption under Section 11. The CIT(A) upheld this decision.

What did the Tribunal hold?

The Tribunal held that corpus donations are capital receipts and exempt from taxation under Section 11(1)(d). Since the assessee's total income was below the taxable limit, filing Form 10B was not mandatory.

What were the issues?

Whether corpus donations are taxable income, and if the non-filing of Form 10B invalidates exemption claims for charitable trusts.

Which sections of the Income-tax Act were involved?

Section 11(1)(d),Section 12(1),Section 12A(1)(b),Section 2(24)(iia),Section 154

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, DELHI BENCH ‘A’, NEW DELHI

Before: SH. SATBEER SINGH GODARA & SH. NAVEEN CHANDRA

For Respondent: Shri Zafarul Haque Tanweer, CIT-D.R
Hearing: 03.08.2026Pronounced: 03.08.2026

PER NAVEEN CHANDRA, ACCOUNTANT MEMBER :

The instant appeal filed by the assessee is directed against the order dated 30.01.2026 passed by the ld. Addl/JCIT(A)-2, Coimbatore [hereinafter referred to as the Ld. CIT(A)] against the rectification order dated 15.12.2022 passed under section 154 of the Income Tax Act (hereinafter referred as ‘the Act’) for Assessment Year 2021-22 by CPC, Benguluru. [A.Y 2021-22]

3.

Assessee filed the following grounds of appeal as under

The order continues below.

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