M/S Bandanthamma Mathu Kalamma Trust, Mysore vs. Income Tax Officer Ward-1(4), Mysore
In the result, the appeals filed by the assessee are allowed
ITA 1764/BANG/2018[2011-12]Status: DisposedITAT Bangalore26 Feb 2020AY 2011-12
Bench: Shri Chandra Poojari, Am & Smt.Beena Pillai, Jm
For Appellant: Sri. Narendra Sharma, AdvocateFor Respondent: Sri.Manjeet Singh, Addl.CIT-DR
Section 12ASection 143Section 143(3)Section 147Section 148Section 2
…us donations made with specific directions will not be treated as income of the Trust or institution. The appellant places its reliance on the Hon'ble Co-Ordinate Bench of Bangalore Tribunal decision in the case of St. Ann's Home for Aged Vs. ITO, reported in 10 TTJ 144. [ix] It is submitted that the voluntary contributions received for a specific purpose cannot be regarded as income, as they do not fall within the ambit of the provisions of section 2[24][iia] of the Act. It is submitted that the principles relating to capital versus revenue have to be considered and the capital receipts cannot be treated as inco…