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“Section 2(24)(iia)”

Section References (mined)Section 2Section 2(24)(iia)48 judgments

AMEENAMMA CHARITBLE TRUST,ANANTAPUR vs. ITO, (EXEMPTION) WARD-TIRUPATI, TIRUPATI

In the result, appeal filed by the assessee Trust is partly allowed in terms of our aforesaid observations

ITA 1841/HYD/2025[2016-17]Status: DisposedITAT Hyderabad20 Feb 2026AY 2016-17

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.1841/Hyd/2025 (िनधा"रण वष"/Assessment Year:2016-17) Ameenamma Charitable Vs. Income Tax Officer Trust, (Exemption) Ward – Anantapur. Tirupati. Pan: Aaeta7403P (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri Ka Sai Prasad, Ca राज" व "ारा/Revenue By: Shri K Vamsi Krishna, Sr.Ar सुनवाई की तारीख/Date Of Hearing: 04/02/2026 घोषणा की तारीख/Date Of 20/02/2026 Pronouncement: आदेश / Order Per. Ravish Sood, J.M: The Present Appeal Filed By The Assessee Trust Is Directed Against The Order Passed By The Additional/Joint Commissioner Of Income Tax (Appeals)-1, Chennai, Dated 03/10/2025, Which In Turn Arises From The Order Passed By The Income Tax Officer, Exemption Ward, Tirupati (For Short, “Ao”) Under Section 143(3) Of The Income Tax Act, 1961 (For Short, “The Act”), Dated 14/12/2018 For The Assessment Year (Ay) 2016-17. The Assessee Has Assailed The Impugned Order Of The Cit(A) On The Following Grounds Of Appeal:

For Appellant: Shri KA Sai Prasad, CAFor Respondent: Shri K Vamsi Krishna, Sr.AR

Section 11Section 11(1)Section 11(2)Section 115BSection 12ASection 13(9)Section 139(1)Section 143(2)Section 143(3)Section 250

reasons: i) “The provisions of sub-section (3) to section 115BBC holds that the anonymous donation means any voluntary contributions referred to in section 2(24)(iia) of the IT Act and in the instant case the amount of Rs 11,78,000/- are absolutely the donations/ contributions obtained

PUBLIC POLITICAL PARTY,DELHI vs. DCIT, CENTRAL CIRCLE 31, DELHI

ITA 2985/DEL/2025[2022-23]Status: DisposedITAT Delhi17 Dec 2025AY 2022-23

Bench: Shri Anubhav Sharma & Shri Amitabh Shukla

For Appellant: Sh. Mohan Lal Sharma, AdvFor Respondent: Sh. Dayainder Singh Sidhu, CIT

Section 132Section 13ASection 143(3)Section 147Section 29ASection 68

voluntary contributions as a head of income under Section 14 or not even deeming it to be income for the purposes of Section 2(24)(iia) of the Act? This requires the discussion to turn to what is meant by 'income from other sources'. An elaboration of this expression occurs ... true that income by way of voluntary contribution of a political party is not deemed to be income under Section 2(24)(iia) of the Act. However that does not place it outside the purview of 'income from other sources' for the purposes of Section 13 A read with Section

PUBLIC POLITICAL PARTY,DELHI vs. DCIT, CENTRAL CIRCLE-31, DELHI

ITA 2984/DEL/2025[2017-18]Status: DisposedITAT Delhi17 Dec 2025AY 2017-18

Bench: Shri Anubhav Sharma & Shri Amitabh Shukla

For Appellant: Sh. Mohan Lal Sharma, AdvFor Respondent: Sh. Dayainder Singh Sidhu, CIT

Section 132Section 13ASection 143(3)Section 147Section 29ASection 68

voluntary contributions as a head of income under Section 14 or not even deeming it to be income for the purposes of Section 2(24)(iia) of the Act? This requires the discussion to turn to what is meant by 'income from other sources'. An elaboration of this expression occurs ... true that income by way of voluntary contribution of a political party is not deemed to be income under Section 2(24)(iia) of the Act. However that does not place it outside the purview of 'income from other sources' for the purposes of Section 13 A read with Section

PUBLIC POLITICAL PARTY,DELHI vs. DCIT, CENTRAL CIRCLE 31, DELHI

ITA 2983/DEL/2025[2016-17]Status: DisposedITAT Delhi17 Dec 2025AY 2016-17

Bench: Shri Anubhav Sharma & Shri Amitabh Shukla

For Appellant: Sh. Mohan Lal Sharma, AdvFor Respondent: Sh. Dayainder Singh Sidhu, CIT

Section 132Section 13ASection 143(3)Section 147Section 29ASection 68

voluntary contributions as a head of income under Section 14 or not even deeming it to be income for the purposes of Section 2(24)(iia) of the Act? This requires the discussion to turn to what is meant by 'income from other sources'. An elaboration of this expression occurs ... true that income by way of voluntary contribution of a political party is not deemed to be income under Section 2(24)(iia) of the Act. However that does not place it outside the purview of 'income from other sources' for the purposes of Section 13 A read with Section

PUBLIC POLITICAL PARTY,DELHI vs. DCIT, CENTRAL CIRCLE-31, DELHI

ITA 2982/DEL/2025[2015-16]Status: DisposedITAT Delhi17 Dec 2025AY 2015-16

Bench: Shri Anubhav Sharma & Shri Amitabh Shukla

For Appellant: Sh. Mohan Lal Sharma, AdvFor Respondent: Sh. Dayainder Singh Sidhu, CIT

Section 132Section 13ASection 143(3)Section 147Section 29ASection 68

voluntary contributions as a head of income under Section 14 or not even deeming it to be income for the purposes of Section 2(24)(iia) of the Act? This requires the discussion to turn to what is meant by 'income from other sources'. An elaboration of this expression occurs ... true that income by way of voluntary contribution of a political party is not deemed to be income under Section 2(24)(iia) of the Act. However that does not place it outside the purview of 'income from other sources' for the purposes of Section 13 A read with Section

PUBLIC POLITICAL PARTY,DELHI vs. DCIT, CENTRAL CIRCLE 31, DELHI

ITA 2966/DEL/2025[2021-22]Status: DisposedITAT Delhi17 Dec 2025AY 2021-22

Bench: Shri Anubhav Sharma & Shri Amitabh Shukla

For Appellant: Sh. Mohan Lal Sharma, AdvFor Respondent: Sh. Dayainder Singh Sidhu, CIT

Section 132Section 13ASection 143(3)Section 147Section 29ASection 68

voluntary contributions as a head of income under Section 14 or not even deeming it to be income for the purposes of Section 2(24)(iia) of the Act? This requires the discussion to turn to what is meant by 'income from other sources'. An elaboration of this expression occurs ... true that income by way of voluntary contribution of a political party is not deemed to be income under Section 2(24)(iia) of the Act. However that does not place it outside the purview of 'income from other sources' for the purposes of Section 13 A read with Section

PUBLIC POLITICAL PARTY,DELHI vs. DCIT, DELHI

ITA 2813/DEL/2025[2020-21]Status: DisposedITAT Delhi17 Dec 2025AY 2020-21

Bench: Shri Anubhav Sharma & Shri Amitabh Shukla

For Appellant: Sh. Mohan Lal Sharma, AdvFor Respondent: Sh. Dayainder Singh Sidhu, CIT

Section 132Section 13ASection 143(3)Section 147Section 29ASection 68

voluntary contributions as a head of income under Section 14 or not even deeming it to be income for the purposes of Section 2(24)(iia) of the Act? This requires the discussion to turn to what is meant by 'income from other sources'. An elaboration of this expression occurs ... true that income by way of voluntary contribution of a political party is not deemed to be income under Section 2(24)(iia) of the Act. However that does not place it outside the purview of 'income from other sources' for the purposes of Section 13 A read with Section

PUBLIC POLITICAL PARTY,DELHI vs. DCIT, DELHI

ITA 2812/DEL/2025[2019-20]Status: DisposedITAT Delhi17 Dec 2025AY 2019-20

Bench: Shri Anubhav Sharma & Shri Amitabh Shukla

For Appellant: Sh. Mohan Lal Sharma, AdvFor Respondent: Sh. Dayainder Singh Sidhu, CIT

Section 132Section 13ASection 143(3)Section 147Section 29ASection 68

voluntary contributions as a head of income under Section 14 or not even deeming it to be income for the purposes of Section 2(24)(iia) of the Act? This requires the discussion to turn to what is meant by 'income from other sources'. An elaboration of this expression occurs ... true that income by way of voluntary contribution of a political party is not deemed to be income under Section 2(24)(iia) of the Act. However that does not place it outside the purview of 'income from other sources' for the purposes of Section 13 A read with Section

PUBLIC POLITICAL PARTY,DELHI vs. DCIT, DELHI

ITA 2761/DEL/2025[2018-19]Status: DisposedITAT Delhi17 Dec 2025AY 2018-19

Bench: Shri Anubhav Sharma & Shri Amitabh Shukla

For Appellant: Sh. Mohan Lal Sharma, AdvFor Respondent: Sh. Dayainder Singh Sidhu, CIT

Section 132Section 13ASection 143(3)Section 147Section 29ASection 68

voluntary contributions as a head of income under Section 14 or not even deeming it to be income for the purposes of Section 2(24)(iia) of the Act? This requires the discussion to turn to what is meant by 'income from other sources'. An elaboration of this expression occurs ... true that income by way of voluntary contribution of a political party is not deemed to be income under Section 2(24)(iia) of the Act. However that does not place it outside the purview of 'income from other sources' for the purposes of Section 13 A read with Section

SHRI PARSHVANATH DIGAMBAR JAIN DHARMIK AND SAMAJIK SANSTHA,RAM GALI, NEEMUCH CANT vs. INCOME TAX OFFICER, AAYKAR BHAWAN INDORE

Appeal is allowed for statistical purpose

ITA 353/IND/2025[2017-2018]Status: DisposedITAT Indore27 Nov 2025AY 2017-2018

Section 115BSection 12ASection 144Section 69A

corpus of the\ntrust or distribution will, however, not be regarded as income.\"\n18. Thus the relevant clause defining income in section 2(24)(iia) as introduced with effect from\n1.4.1973 was clearly not intended to cover contributions/donations received with a specific\ndirection that they will form part ... nsection 2(24)(iia) of the Income-tax Act and in this decision, it has been held as under :\n'So far as section 2(24) (iia) is concerned, this section has to be read in the context of the\nintroduction of the present section 12 it is significant that

DUDHSAGAR RESEARCH AND DEMENT ASSOCIATION,MEHSANA vs. THE DY.CIT, CIRCLE-1, EXEMPTION, AHMEDABAD

In the result, the appeal of the assessee is partly allowed

ITA 203/AHD/2025[2017-18]Status: DisposedITAT Ahmedabad17 Nov 2025AY 2017-18

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

For Appellant: Shri S N Divatia, ARFor Respondent: Shri R P Rastogi, CIT-DR

Section 11Section 11(1)(d)Section 13(8)Section 2(15)Section 250

hence did not qualify as a corpus donation under section 11(1)(d). He therefore brought the amount to tax as income under section 2(24)(iia) and completed the assessment at total income of Rs. 6,41,81,500/-. ITA Nos. 202&203/Ahd/2025 Dudhsagar Research and Dement Association

DUDHSAGAR RESEARCH AND DEMENT ASSOCIATION,MEHSANA vs. THE DY.CIT, CICLE-1, EXEMPTION, AHMEDABAD

In the result, the appeal of the assessee is partly allowed

ITA 202/AHD/2025[2016-17]Status: DisposedITAT Ahmedabad17 Nov 2025AY 2016-17

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

For Appellant: Shri S N Divatia, ARFor Respondent: Shri R P Rastogi, CIT-DR

Section 11Section 11(1)(d)Section 13(8)Section 2(15)Section 250

hence did not qualify as a corpus donation under section 11(1)(d). He therefore brought the amount to tax as income under section 2(24)(iia) and completed the assessment at total income of Rs. 6,41,81,500/-. ITA Nos. 202&203/Ahd/2025 Dudhsagar Research and Dement Association

SANGAMNER MEDICAL FOUNDATION AND RESEARCH INSTITUTE,AHMEDNAGAR vs. EXEMPTION CIRCLE AURANGABAD, AHMEDNAGAR

In the result, the appeal filed by the assessee is treated as allowed for statistical purposes

ITA 900/PUN/2025[2018-19]Status: DisposedITAT Pune26 Aug 2025AY 2018-19

Bench: Shri R.K. Panda & Ms. Astha Chandra

For Appellant: Shri Suhas BoraFor Respondent: Shri Akhilesh Srivastva

Section 115BSection 12ASection 133(6)Section 142(1)Section 143(2)Section 143(3)Section 80Section 80G

list of donors submitted lacks credibility and may not accurately reflect the true nature of the alleged donations. Furthermore, Section 115BBC and Section 2(24)(iia) are included in the statute to prevent the introduction of unaccounted funds from the public or donors into charitable activities, irrespective of the fact

INCOME TAX OFFICER, EXEMPTIONS WARD, TRICHY, TRICHY vs. ARULMIGU SWAMINATHA SWAMI THIRUKKOVIL, KUMBAKONAM

In the result, the appeals filed by the revenue in ITA Nos

ITA 370/CHNY/2025[2013]Status: DisposedITAT Chennai30 Jul 2025

Bench: Shri S.S.Viswanethra Ravi & Shri S.R.Raghunathaआयकर अपील सं./Ita Nos.: 370 & 368/Chny/2025 & Co Nos.32 & 33/Chny/2025 (In Ita Nos.: 370 & 368/Chny/2025) धनिाारण वर्ा / Assessment Year: 2013-14 & 2014-15 Income Tax Officer, Arulmigu Swaminatha Swami Exemptions Ward, Trichy, Thirukkovil, Vs. The Executive Officer, Swamimalai, Kumbakonam – 612 301. [Pan: Aaata-6446-J] (अपीलाथी/Appellant) (Respondent/Cross Objector) अपीलाथीकीओरसे/ Appellant By : Shri. P. Krishna Kumar, J.C.I.T. प्रत्यथीकीओरसे/Respondent By : Shri. N. Arjun Raj, Advocate सुनवाई की तारीख/Date Of Hearing : 09.05.2025 घोर्णा की तारीख/Date Of Pronouncement : 30.07.2025 आदेश /O R D E R Per Bench: These Appeals Filed By The Revenue & Cross Objections Filed By The Assessee Are Directed Against The Order Of The Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi, For The Assessment Years 2013-14 & 2014-15, Vide Order Dated 20.12.2024. Since The Facts Are Identical & Issues Are Common, Appeals Filed By The Revenue & Cross Objections Filed By The Assessee Were Heard & Are Being Disposed Of By This Consolidated Order.

For Appellant: Shri. P. Krishna Kumar, J.C.I.TFor Respondent: Shri. N. Arjun Raj, Advocate

Section 10Section 11Section 12A(1)(b)Section 139Section 139(1)Section 147

denial of exemption on technical breach would defy the principles of fairness in taxation. 31. We find that the definition of income in Section 2(24)(iia) of the Act, the voluntary contribution does not generally have the character of income but deemed income in case of non-corpus donations

THE INCOME TAX OFFICER, EXEMPTIONS WARD, TRICHY, TRICHY vs. ARULMIGU SWAMINATHA SWAMI THIRUKKOVIL, KUMBAKONAM

In the result, the appeals filed by the revenue in ITA Nos

ITA 368/CHNY/2025[2014-15]Status: DisposedITAT Chennai30 Jul 2025AY 2014-15

Bench: Shri S.S.Viswanethra Ravi & Shri S.R.Raghunathaआयकर अपील सं./Ita Nos.: 370 & 368/Chny/2025 & Co Nos.32 & 33/Chny/2025 (In Ita Nos.: 370 & 368/Chny/2025) धनिाारण वर्ा / Assessment Year: 2013-14 & 2014-15 Income Tax Officer, Arulmigu Swaminatha Swami Exemptions Ward, Trichy, Thirukkovil, Vs. The Executive Officer, Swamimalai, Kumbakonam – 612 301. [Pan: Aaata-6446-J] (अपीलाथी/Appellant) (Respondent/Cross Objector) अपीलाथीकीओरसे/ Appellant By : Shri. P. Krishna Kumar, J.C.I.T. प्रत्यथीकीओरसे/Respondent By : Shri. N. Arjun Raj, Advocate सुनवाई की तारीख/Date Of Hearing : 09.05.2025 घोर्णा की तारीख/Date Of Pronouncement : 30.07.2025 आदेश /O R D E R Per Bench: These Appeals Filed By The Revenue & Cross Objections Filed By The Assessee Are Directed Against The Order Of The Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi, For The Assessment Years 2013-14 & 2014-15, Vide Order Dated 20.12.2024. Since The Facts Are Identical & Issues Are Common, Appeals Filed By The Revenue & Cross Objections Filed By The Assessee Were Heard & Are Being Disposed Of By This Consolidated Order.

For Appellant: Shri. P. Krishna Kumar, J.C.I.TFor Respondent: Shri. N. Arjun Raj, Advocate

Section 10Section 11Section 12A(1)(b)Section 139Section 139(1)Section 147

denial of exemption on technical breach would defy the principles of fairness in taxation. 31. We find that the definition of income in Section 2(24)(iia) of the Act, the voluntary contribution does not generally have the character of income but deemed income in case of non-corpus donations

RAM PARSAD DAV PUBLIC SCHOOL SOCIETY,MARKANDA vs. ITO (EXEMPTIONS), WARD, AMBALA

In the result, appeal of the Assessee is allowed for statistical purposes

ITA 752/CHANDI/2022[2016-17]Status: DisposedITAT Chandigarh30 Jun 2025AY 2016-17

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. MANOJ KUMAR AGGARWAL (Accountant Member)

For Appellant: Shri Vibhor Garg, C.AFor Respondent: Dr. Ranjit Kaur, Addl. CIT, Sr. DR

Section 10Section 11(1)(d)Section 12ASection 143(3)Section 2(24)(iia)Section 250(4)Section 250(6)Section 251(2)Section 271(1)(c)

found the assessee neither registered under Section 12AA nor approved under Section 10(23C)(vi), rendering the donation taxable as income under Section 2(24)(iia) and ineligible for exemption under Section 11(1)(d). The AO recomputed the taxable income by adding the donation to gross receipts, resulting ... claim for exemption under Section 10(23C)(vi) and the taxability of the donation 4 amounting to Rs. 2,52,325/- under Section 2(24)(iia). In light of these procedural lapses and the necessity for factual verification of the assessee’s claims, the matter is remanded to the file

M/S SURYA WORLD EDUCATIONAL RESEARCH AND CHARITABLE INSTITUTE,RAJPURA vs. DCIT , CC-I, CHANDIGARH

In the result, the appeal filed by the assessee is dismissed both for non- prosecution and on merits

ITA 879/CHANDI/2018[2011-12]Status: DisposedITAT Chandigarh03 Jun 2025AY 2011-12

Bench: Us. Therefore, For The Sake Of Convenience & To Avoid Repetition, We Are Taking Ita No. 879/Del/2018 As The Lead Appeal & Reproducing The Facts, Grounds Raised & The Order Passed By The Ld. Cit(A)Karnal, For Completeness. 2. The Case Was Listed For Hearing On 29/5/2025 , When The Matter Was Called, There Was No Appearance From The Side Of The Assessee. It Is Noted From The Record That Earlier Mr. Tej Mohan, Advocate, Was Appearing On Behalf Of The Assessee. However, No Adjournment Request Or Explanation For Non-Appearance Has Been Filed. The Conduct Of The Assessee Indicates A Lack Of Interest In Prosecuting The Appeal. However, Considering Non- Appearance On Behalf Of The Assessee On Many Earlier Occasions & The Nature Of The Issues Involved, We Proceed To Decide The Appeal On Merits As Well.

For Appellant: NoneFor Respondent: Smt. Kusum Bansal, CIT, DR (Virtual Mode)

received as referred to in clause (i). (2) For the purposes of this section, "anonymous donation" means any voluntary contribution referred to in section 2(24)(iia), where a person receiving such contribution does not maintain a record of— (i) the name and address of the person making such contribution

M/S SURYA WORLD EDUCATIONAL RESEARCH AND CHARITABLE INSTITUTE,RAJPURA vs. DCIT , CC-I, CHANDIGARH

In the result, the appeal filed by the assessee is dismissed both for non- prosecution and on merits

ITA 878/CHANDI/2018[2010-11]Status: DisposedITAT Chandigarh03 Jun 2025AY 2010-11

Bench: Us. Therefore, For The Sake Of Convenience & To Avoid Repetition, We Are Taking Ita No. 879/Del/2018 As The Lead Appeal & Reproducing The Facts, Grounds Raised & The Order Passed By The Ld. Cit(A)Karnal, For Completeness. 2. The Case Was Listed For Hearing On 29/5/2025 , When The Matter Was Called, There Was No Appearance From The Side Of The Assessee. It Is Noted From The Record That Earlier Mr. Tej Mohan, Advocate, Was Appearing On Behalf Of The Assessee. However, No Adjournment Request Or Explanation For Non-Appearance Has Been Filed. The Conduct Of The Assessee Indicates A Lack Of Interest In Prosecuting The Appeal. However, Considering Non- Appearance On Behalf Of The Assessee On Many Earlier Occasions & The Nature Of The Issues Involved, We Proceed To Decide The Appeal On Merits As Well.

For Appellant: NoneFor Respondent: Smt. Kusum Bansal, CIT, DR (Virtual Mode)

received as referred to in clause (i). (2) For the purposes of this section, "anonymous donation" means any voluntary contribution referred to in section 2(24)(iia), where a person receiving such contribution does not maintain a record of— (i) the name and address of the person making such contribution

CREDIT GUARNTEE FUND TRUST FOR MICRO AND SMALL ENTERPRISES,MUMBAI vs. DCIT (E)_1(1), MUMBAI

In the result, appeal of the assessee is allowed

ITA 5834/MUM/2024[2013-14]Status: DisposedITAT Mumbai27 Mar 2025AY 2013-14

Bench: the CIT(A) against the aforesaid Assessment Order which was dismissed, vide order dated 30/09/2024. Now, being aggrieved the Assessee-trust has preferred the present appeal before the Tribunal.

For Appellant: Shri Bhupendra KarkhanisFor Respondent: Shri R.A. Dhyani

Section 11Section 12ASection 143(3)Section 2(24)Section 2(24)(iia)Section 250

Assessment Year 2012-2013 [ITA No. 2045/Mum/2024, dated 25/07/2024] we find that the Tribunal had (a) deleted the addition made under Section 2(24)(iia) of the Act holding the contribution received from settlors as income of the Assessee and (b) directed the Assessing Officer to grant benefit in terms

CREDIT GUARANTEE FUND TRUST FOR MICRO AND SMALL ENTERPRISES ,MUMBAI vs. DCIT EXEMPTION-1(1), MUMBAI

In the result the appeal filed by the assessee stands allowed for statistical purposes

ITA 179/MUM/2025[2015-16]Status: DisposedITAT Mumbai06 Mar 2025AY 2015-16

Bench: Hon’Ble Shri Sandeep Gosain & Hon’Ble Shri Prabhash Shankarcredit Guarantee Fund Vs. Dcit(E) – 1(1) Trust Mumbai. 1St Floor, Sidbi Swavalaman Bhavan, Avenue – 3, Lane 2, G-Block, Bkc, Bandra (E) Pan/Gir No. Aaatc2613D (Applicant) (Respondent)

Section 11(1)(a)Section 11(1)(d)Section 12ASection 143(1)Section 2(24)Section 2(24)(iia)Section 250

Settlors as per Trust deed cannot be treated as income of the Trust. The same is not voluntary contributions within the meaning of Section 2(24)(iia) of the Act. It was also submitted that as the trust's registration u/s 12A was in force, the provisions of Section ... Income by virtue of provisions of section 11(1)(d) of the Act and hence cannot fall into the definition of "income" under section 2(24)(iia) of the Act and cannot be taxed in the hands of the appellant. .7 Similar addition of contribution from settlors was also made

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