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“anonymous donation”

Charitable TrustsSection 115BBCSection 115BBC175 judgments

The decision most relied on for anonymous donation is CIT v. Halai Namon Association ( (330 ITR 24), cited in 33 judgments on BharatTax.

Leading authorities on anonymous donation

Judgments citing anonymous donation

Narayani Siddhar Peedam Charitable Trust, Vellore vs. DDIT (Exemptions-III), Chennai

ITA 1532/CHNY/2025[2011-12]Status: DisposedITAT Chennai26 Nov 2025AY 2011-12

Bench: Shri George George K & Shri Jagadishआयकर अपील सं./Ita No.: 1532/Chny/2025 निर्धारण वर्ष/Assessment Year: 2011-12 Shri Narayani Siddhar Peedam Charitable Trust, Rep. By Trustee, K. Soundararajan, Thirumalaikodi, Ariyur Village, Vellore 632 055. Pan: Aaatn 3254F (अपीलार्थी/Appellant) अपीलार्थी की ओर से/Appellant By प्रत्यर्थी की ओर से/Respondent By सुनवाई की तारीख/Date Of Hearing घोषणा की तारीख/Date Of Pronouncement The Deputy Director Of Vs. Income Tax, (Exemptions – Iii) Chennai (प्रत्यर्थी/Respondent) : Shri N. Muralikumaran, Sr. Advocate : Ms. Mythili, Jcit : 25.11.2025 : 26.11.2025 आदेश/Order Per George George K: This Appeal Filed By The Assessee Is Directed Against The Order Of Addl/Jcit(A)-5, Mumbai Dated 29.03.2025, Passed Under Section 250 Of The Income Tax Act, 1961 (Hereinafter Called 'The Act'). The Relevant Assessment Year Is 2011-12. :- 2 -:

Section 115BSection 12ASection 143(2)Section 143(3)Section 250Section 80G(5)(vi)

case of Sundeer Deep Educational Society (supra) reads as follows:- :- 6 -: ITA No.1532/Chny/2025 "S. 11 Law on taxability of voluntary donations as "anonymous donations" u/s_115BBC_or as "cash credit" uls 68 in hands of chantable trust explained The assessee, a charitable institution, received donations of Rs.3.55 crore. It maintained a record ... letters came back undelivered or were not replied to. The AO held that as the confirmations were not received, the said donations were “anonymous donations

Menaba Charitable Trust, Ahmedabad vs. The ITO, Ward-1(Exemptions), Ahmedabad

ITA 1361/AHD/2025[2017-18]Status: DisposedITAT Ahmedabad06 Nov 2025AY 2017-18

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyalआयकर अपील सं /Ita No.1361/Ahd/2025 िनधा"रण वष" /Assessment Year : 2017-18 Menaba Charitable Trust The Ito बनाम/ 26, Mahavir Jain Soc., Ward-1 (Exemptions) V/S. Bapunagar Ahmedabad – 380 015 Ahmedabad – 380 024 "थायी लेखा सं./Pan: Aaatm 2171 N (अपीलाथ"/ Appellant) ("" यथ"/ Respondent) Assessee By : Shri Rushin Patel, Ar Revenue By : Shri C Dharani Nath, Sr.Dr सुनवाई की तारीख/Date Of Hearing : 17/09/2025 घोषणा की तारीख /Date Of Pronouncement: 06/11/2025 आदेश/O R D E R Per Siddhartha Nautiyal, Jm: The Present Appeal Has Been Preferred By The Assessee Against The Order Of The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi [Hereinafter Referred To As ‘Cit(A)’] Dated 24/12/2024 Passed U/S.250 Of The Income Tax Act, 1961 (Hereinafter Referred To As ‘The Act’) For The Assessment Year (Ay) 2017-2018. 2. The Assessee Raised The Following Grounds Of Appeal:

For Appellant: Shri Rushin Patel, ARFor Respondent: Shri C Dharani Nath, Sr.DR
Section 11Section 115BSection 250

facts in making the addition of Rs.32,74,493/- to the total income of the appellant on account of treating donations as the 'anonymous donation' under section 115BBC of the Income Tax Act. 1.3 That the learned assessing officer has erred in making the addition on account of anonymous donation ... beyond the purview of the exemption under section 11 and 12 of the Income Tax Act, 1961 on account of 'anonymous donations' despite the fact that any voluntary contribution received by a Charitable or religious trust shall be deemed to be income derived from property held under Trust to extent

Nir Ideal Home for Mentally Retarded and Associated Disability, Haroa vs. ITO, Ward 1(1), Exempt, Kolkata

Accordingly the grounds raised by the appellant in this regard are dismissed”

ITA 1376/KOL/2025[2022-2023]Status: DisposedITAT Kolkata30 Oct 2025AY 2022-2023

Bench: Shri Duvvuru Rl Reddy, Vice-(Kz) I.T.A. No. 1376/Kol/2025 Assessment Year: 2022-2023 Nir Ideal Home For Mentally Retarded & Associated Disability,………………..……Appellant Vill. Pilkhana, Haroa, North 24-Parganas-743425, West Bengal [Pan:Aaaan3642G] -Vs.- Income Tax Officer,……………………………....Respondent Ward-1(1), Exemption, Kolkata, (Assessment Unit, Income Tax Department), Income Tax Building, 10B, Middleton Row, Kolkata-700071 Appearances By: Shri Arvind Agrawal, A.R., Appeared On Behalf Of The Assessee Shri Mrinmay Basak, Sr. D.R., Appeared On Behalf Of The Revenue Date Of Concluding The Hearing: August 28, 2025 Date Of Pronouncing The Order: October 30, 2025 O R D E R

Section 115BSection 143(2)Section 80G

furnished its reply along with Memorandum of Association, audited financials and computation of income for the AY 2022-23. The appellant claimed that the anonymous donation received during the year under consideration of Rs.17,65,436/- should not be treated as violation of section 115BBC as the Trust comes under ... religious’ 2 Nir Ideal Home For Mentally Retarded And Associated Disability nature to claim such exception and hence, the ld. Assessing Officer brought the anonymous donations of Rs.17,65,436/- received during the year under consideration to tax as per the provisions of section 115BBC

Shri Mahaveer Charitable Trust, Allahabad vs. ITO(Exemption), Allahabad

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

ITA 181/ALLD/2024[2013-14]Status: DisposedITAT Allahabad14 Oct 2025AY 2013-14

Bench: Sh. Subhash Malguria & Sh. Nikhil Choudharya.Y. 2013-14 Shri Mahaveer Charitable Trust, Vs Income Tax Officer 46, Rajendra Nagar, Baluaghat, (Exemption), Allahabad Allahabad-211003, U.P. Pan: Aahts9123K (Appellant) (Respondent) Assessee By: Dr. Pawan Jaiswal & Sh. Ajit Kumar, Advocates Revenue By: Sh. A.K. Singh, Sr. Dr Date Of Hearing: 22.07.2025 Date Of 14.10.2025 Pronouncement: O R D E R Per Nikhil Choudhary, A.M. This Is An Appeal Filed By The Assessee Against The Order Of The Ld. Cit, Nfac Dated 28.09.2024, Wherein The Ld. Cit(A) Has Dismissed The Appeal Of The Assessee That Was Filed Against The Orders Of The Income Tax Officer (Exemption), Allahabad Dated 30.03.2018. The Grounds Of Appeal Are As Under: - “1. Because The Impugned Order Of The Ld. Cit(A) Dated 28.09.2024 Affirming The Addition Of Rs. 1,97,69,650/- On Account Of Donation Received & Rejection Of The Submissions Of The Appellant That Appeal Proceedings Pending Against The Order Passed Under Section 143(3) Dated 30.03.2016 Are Infructuous Is Absolutely Illegal & Against The Principles Of Law. 2. Because The Hon'Ble Supreme Court In The Case Of Cit V. Alagendran Finance Ltd. [27.07.2007] Had Observed That When An Order Of Assessment Is Reopened, The Previous Assessment Will Be Held To Be Set Aside & The Whole Proceedings Would Start Afresh & In The Case In Hands The Assessment Order Dated 30.03.2016 Has Been Set-Aside By The Then Incumbent Ld. Cit(E); That Is To Say That No Assessment Existed On The Date When Order Dated 28.02.2018 Under Section 263 Of The Act Was Passed By The Then Incumbent Cit(E). 3. Because Section 263 Of The Act Grants Power To The Jurisdictional Commissioner To Direct For Revision Of Orders & Reads As Under (Relevant Statute Quoted):

For Appellant: Dr. Pawan Jaiswal & Sh. Ajit Kumar, AdvocatesFor Respondent: Sh. A.K. Singh, Sr. DR
Section 143(3)Section 263

scrutiny assessment under section 143(3) at a total income of rupees Nil. However, the donations of Rs.1,97,69,650/-. were treated as anonymous donations and therefore, were brought to tax under section 115BBC of the Income Tax Act, 1961. 3. Being aggrieved by the said assessment order ... could attract the provisions of section 68 of the Income Tax Act, 1961. The ld. CIT (Exemption) had further observed that even though the anonymous donations amounting to Rs. 1,97,69,650/- had been charged to tax under section 115BBC, the interest under section 234A and 234B

Aryans Educational and Charitable Trust Regd, Mohali vs. Commissioner of Income Tax, Exemptions, Chandigarh

In the result, appeal is allowed

ITA 1136/CHANDI/2024[2025-26]Status: DisposedITAT Chandigarh24 Sept 2025AY 2025-26

Bench: Shri Rajpal Yadav & Shri Krinwant Sahayआयकर अपील सं./ Ita No. 1136/Chd/2024 "नधा"रण वष" / Assessment Year: 2025-26 Aryans Educational & The Cit (Exemptions), Charitable Trust, Regd.Mohali Vs Chandigarh, C/O Shri Tej Mohan Singh, Advocate, # 527, Sector 10-D, Chandigarh. "थायी लेखा सं./Pan No: Aabta7550L अपीलाथ"/Appellant ""यथ"/Respondent Assessee By : Shri Tej Mohan Singh, Advocate Revenue By : Shri Manav Bansal, Cit Dr Date Of Hearing : 07.08.2025 Date Of Pronouncement : 24.09.2025

For Appellant: Shri Tej Mohan Singh, AdvocateFor Respondent: Shri Manav Bansal, CIT DR
Section 11Section 12ASection 12A(1)(ac)Section 13(1)(c)Section 13(1)(ii)Section 13(3)

applying the provisions of section 115BBC and section 68 of the Act treating corpus donations received from students to be anonymous donations. 8. We find that the not considering the evidence filed by the Assessee during the appellate proceedings before the ld. CIT(A) is not justified on the part ... further been mentioned in the notice that the trust funds were being misused to the advantage of trustees/chairman and on account of receipts being anonymous donations masqueraded as receipts from students. It is pertinent to mention here that the A.Y.2025-26 11 Hon'ble ITAT has already deleted the additions made

Shree Jain Swethambar Murti Pujak Sangh, Chennai vs. ITO, Exemptions Ward-4, Chennai

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

ITA 1994/CHNY/2025[2019-20]Status: DisposedITAT Chennai17 Sept 2025AY 2019-20

Bench: Shri George George Kand Shri S.R. Raghunathaआयकर अपील सं./Ita No.: 1994/Chny/2025 िनधा"रण वष"/Assessment Year:2019-20 M/S. Shree Jain Swethambar The Income Tax Officer, Murti Pujak Sangh, Vs. Exemptions Ward 4, 55, Thirumalai Raja Puram, Chennai. Avadi, Chennai – 600 054. Pan: Aagts 7268G (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri Hitesh, Advocate For Shri D. Anand, Advocate ""यथ" क" ओर से/Respondent By : Ms. Gouthami Manivasagam, Jcit सुनवाई क" तारीख/Date Of Hearing : 17.09.2025 घोषणा क" तारीख/Date Of Pronouncement : 17.09.2025

For Appellant: Shri Hitesh, AdvocateFor Respondent: Ms. Gouthami Manivasagam, JCIT
Section 115BSection 142(1)Section 143(2)Section 143(3)Section 250

solitary issue raised is whether the First Appellate Authority (FAA) is justified in confirming the addition of Rs.1,26,453/- as anonymous donations. 3. Brief facts of the case are as follows: The assessee is a trust. For the assessment year 2019-20, the return of income was filed declaring ... r.w.s. 144B of the Act vide order dated 27.08.2021. In the said assessment order, the AO made addition of Rs.1,26,453/- as anonymous donations since assessee did not submit the requisite details of the donors. 4. Aggrieved by the assessment order making addition of Rs.1,26,453/- assessee filed

Income Tax Officer, Exemptions Ward, 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

facts of the case, the source for cash deposits was undisputedly from the hundial collections/offerings from the devotees / public at large and the anonymous donations received by the religious entity under the Act would be outside the scope of the charging provisions of the Act especially considering the exceptions carved

The Income Tax Officer, Exemptions Ward, 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

facts of the case, the source for cash deposits was undisputedly from the hundial collections/offerings from the devotees / public at large and the anonymous donations received by the religious entity under the Act would be outside the scope of the charging provisions of the Act especially considering the exceptions carved