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“corpus donation”

Charitable TrustsSection 11(1)(d)Section 11(1)(d)517 judgments

B R MORDEM SCHOOL SAMITI,PAURI vs. I T O, EXEMPTION WARD DEHRADUN, DEHRADUN

In the result, the appeal of the assessee is allowed

ITA 27/DDN/2026[2016-17]Status: DisposedITAT Dehradun13 Mar 2026AY 2016-17
Section 10Section 12ASection 143(3)Section 148Section 250

exemption aggrieved the Dept. went\nin appeal before the Hon. ITAT, which upheld CIT (A)'s\norder and held that-\nThe amounts contributed, as corpus donations for\nInfrastructure development shall form part of corpus\nwould not constitute income of the society. Therefore,\nthe receipts of the educational institution are below ... receipts. Consequently, the assessee's annual receipts were below the threshold.", "result": "Allowed", "sections": [ "10(23C)(iiiad)", "250", "143(3)", "148", "12AA" ], "issues": "Whether corpus donations for building fund should be included in aggregate annual receipts for the purpose of exemption under Section 10(23C)(iiiad

HYDERABAD SCIENCE SOCIETY,HYDERABAD vs. DCIT., EXEMPTION CIRCLE 1(1), HYDERABAD

In the result, appeal of the Assessee is allowed

ITA 1128/HYD/2024[2015-16]Status: DisposedITAT Hyderabad11 Mar 2026AY 2015-16

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं /Ita No.1128/Hyd/2024 Assessment Year 2015-2016 Hyderabad Science Society, Hyderabad. The Dcit, Vs. Pin - 500 028. Exemption Circle-1(1), Telangana. Hyderabad. Pan Aaath3789F (Appellant) (Respondent) For Assessee : Sri P Murali Mohan Rao, Ca For Revenue : Dr. Narendra Kumar Naik, Cit-Dr Date Of Hearing : 12.02.2026 Date Of Pronouncement : 11.03.2026 आदेश/Order

For Appellant: Sri P Murali Mohan Rao, CAFor Respondent: Dr. Narendra Kumar Naik, CIT-DR
Section 12ASection 143Section 143(3)

issue which has been raised by the Id CIT(E) in the show cause notice dated 6.10.2022 is the details of the corpus donation. Admittedly, this was the subject matter of 263 proceedings and that the issue had been considered by the Hon'ble Jurisdictional High Court

SIR CV RAMAN EDUCATIONAL AND CHARITABLE TRUST,CHENNAI vs. CIT, EXEMPTIONS,, CHENNAI

In the result, both the appeals of the assessee are allowed

ITA 2941/CHNY/2025[2025-26]Status: DisposedITAT Chennai04 Mar 2026AY 2025-26

Bench: Shri Aby T. Varkey & Ms. Padmavathy. S

For Appellant: Mr.Y. Sridhar, FCAFor Respondent: Mr.Bipin C.N., CIT
Section 12ASection 12A(1)(ac)Section 80G

assessee trust. To demonstrate the same, the Ld. AR showed us that once the provisional registration was received, the assessee trust had received corpus donations in FYs 2024- 25 and FY 2025-26, which assisted in furtherance of the objects of the assessee trust. Accordingly, on these given facts

SIR CV RAMAN EDUCATIONAL AND CHARITABLE TRUST,CHENNAI vs. CIT, EXEMPTIONS,, CHENNAI

In the result, both the appeals of the assessee are allowed

ITA 2940/CHNY/2025[2025-26]Status: DisposedITAT Chennai04 Mar 2026AY 2025-26

Bench: Shri Aby T. Varkey & Ms. Padmavathy. S

For Appellant: Mr.Y. Sridhar, FCAFor Respondent: Mr.Bipin C.N., CIT
Section 12ASection 12A(1)(ac)Section 80G

assessee trust. To demonstrate the same, the Ld. AR showed us that once the provisional registration was received, the assessee trust had received corpus donations in FYs 2024- 25 and FY 2025-26, which assisted in furtherance of the objects of the assessee trust. Accordingly, on these given facts

NEW HOPE SOCIETY,BERHAMPUR vs. ITO EXEMPTION, BERHAMPUR

In the result, this appeal of the assessee is dismissed

ITA 44/CTK/2026[2016-17]Status: DisposedITAT Cuttack23 Feb 2026AY 2016-17

Bench: Shri George Mathan & Shri Madhusudan Sawdianew Hope Society, I.T.O., C/O- New Hope Society Main Road, Exemption Ward, Vs. Hillpatna, Berhampur-760005 (Odisha) Berhampur. Pan No. Aabtn 1122 D Appellant/ Assessee Respondent/ Revenue

assessment, the Assessing Officer had brought to tax an amount of Rs. 51,92,000/- shown by the assessee in its balance sheet as corpus donations. It was the submission that the said amount was received towards the laboratory equipment cost which has been directly taken to the balance sheet ... line with the maximum fees permissible to be collected by the government. Admittedly, 3 New Hope Society Vs ITO (E) this is not a corpus donation. This being so, we find no error in the orders of the Assessing Officer and the ld. CIT(A) which calls for any interference

DCIT, CENTRAL CIRCLE 7(1), MUMBAI vs. DR D Y PATIL EDUCATIONAL ACADEMY, MUMBAI

In the result, the appeal filed by the revenue stands\ndismissed

ITA 3922/MUM/2025[2015]Status: DisposedITAT Mumbai10 Feb 2026
Section 132Section 153CSection 250Section 68

addition made under\nSection 68 of 1 the I.T. Act, 1961, ignoring the\ncorroborative evidences and statements establishing the\nnon-genuine nature of corpus donations\n\n2.\nOn facts and circumstances of the case and in law,\nthe Ld. CIT(A) failed to appreciate the clear nexus between\nthe donations ... fact\nthat the appellants have received donation of Rs 2,00,00,000 from\nPodar Group.\n\n1.4. The appellants submit that the aforesaid corpus donation is\nsupported by the following documents\n(a) Donation letter dated 26th June, 14 refer page no 31 of the\npaper book

DCIT CENTRAL CIRCLE 7 (1) , MUMBAI vs. DR D Y PATIL EDUCATIONAL ACADEMY, MUMBAI

In the result, both the appeals filed by the revenue are dismissed

ITA 2289/MUM/2025[2015-16]Status: DisposedITAT Mumbai10 Feb 2026AY 2015-16

Bench: Hon’Ble Shri Sandeep Gosain & Shri Girish Agrawal

Section 12ASection 132Section 132(4)Section 153Section 250

statements was that based on the materials seized during the course of search, the deponents have Dr.D Y Patil Educational Academy., Mumbai. stated that corpus donations taken by the Appellant Trust group entities from Donors were in lieu of admissions given to various students in their group entity i.e. Padmashree ... voluntary and involuntary contribution "The only distinction recognized by law is the voluntary contributions to be treated as income under section 12 and the corpus donations to be treated as capital receipt under section 11(1)(d). The corpus donations are not generally in the nature of income. The voluntary

DCIT CENTRAL CIRCLE 7 (1) , MUMBAI vs. DR D Y PATIL EDUCATIONAL ACADEMY, MUMBAI

In the result, both the appeals filed by the revenue are dismissed

ITA 2251/MUM/2025[2017-18]Status: DisposedITAT Mumbai10 Feb 2026AY 2017-18

Bench: Hon’Ble Shri Sandeep Gosain & Shri Girish Agrawal

Section 12ASection 132Section 132(4)Section 153Section 250

statements was that based on the materials seized during the course of search, the deponents have Dr.D Y Patil Educational Academy., Mumbai. stated that corpus donations taken by the Appellant Trust group entities from Donors were in lieu of admissions given to various students in their group entity i.e. Padmashree ... voluntary and involuntary contribution "The only distinction recognized by law is the voluntary contributions to be treated as income under section 12 and the corpus donations to be treated as capital receipt under section 11(1)(d). The corpus donations are not generally in the nature of income. The voluntary

DCIT(EXEMPTIONS)-1(1), MUMBAI, MUMBAI vs. ADITYA BIRLA FOUNDATION, MUMBAI

The appeals of the Revenue are dismissed

ITA 7609/MUM/2025[2017-18]Status: DisposedITAT Mumbai05 Feb 2026AY 2017-18

Bench: Shri Amit Shukla & Shri Makarand Vasant Mahadeokar & Dcit(Exemption)-1(1), Aditya Birla 6Th Floor, Mtnl Foundation, Building, Pedder Road, Vs. C-1, Aditya Birla Cumballa Hills, Centre, S. K. Mumbai-400 026 Ahiremarg, Worli, Mumbai-400 030 Pan/Gir No. Aaata0382P (Applicant) (Respondent) Assessee By Shri Ronak Doshi & Shri Surajsingh Devda, Ld. Ars Revenue By Shri Surendra Mohan, Ld. Dr Date Of Hearing 28.01.2026 Date Of Pronouncement 05.02.2026

Section 11Section 12ASection 13Section 13(1)(c)Section 13(2)(a)Section 13(3)Section 250

that the entire arrangement of leasing out the hospital to a group concern was a colourable device and a scheme of tax planning, whereby corpus donations were collected thereafter leased to a related entity at low rent. 11. For both the years under consideration the assessments were completed

DCIT(EXEMPTIONS)-1(1), MUMBAI, MUMBAI vs. ADITYA BIRLA FOUNDATION, MUMBAI

The appeals of the Revenue are dismissed

ITA 7608/MUM/2025[2016-17]Status: DisposedITAT Mumbai05 Feb 2026AY 2016-17

Bench: Shri Amit Shukla & Shri Makarand Vasant Mahadeokar & Dcit(Exemption)-1(1), Aditya Birla 6Th Floor, Mtnl Foundation, Building, Pedder Road, Vs. C-1, Aditya Birla Cumballa Hills, Centre, S. K. Mumbai-400 026 Ahiremarg, Worli, Mumbai-400 030 Pan/Gir No. Aaata0382P (Applicant) (Respondent) Assessee By Shri Ronak Doshi & Shri Surajsingh Devda, Ld. Ars Revenue By Shri Surendra Mohan, Ld. Dr Date Of Hearing 28.01.2026 Date Of Pronouncement 05.02.2026

Section 11Section 12ASection 13Section 13(1)(c)Section 13(2)(a)Section 13(3)Section 250

that the entire arrangement of leasing out the hospital to a group concern was a colourable device and a scheme of tax planning, whereby corpus donations were collected thereafter leased to a related entity at low rent. 11. For both the years under consideration the assessments were completed

ZABSANG CHOEKHORLING MONASTERY,JOGINDER NAGAR MANDI H.P vs. INCOME TAX OFFICER EXEMPTION WARD SOLAN, SOLAN

The appeal stands allowed for statistical purposes

ITA 356/CHANDI/2025[2018-2019]Status: DisposedITAT Chandigarh04 Feb 2026AY 2018-2019

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकर अपील सं. / Ita No.356/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2018-19) Zabsang Choekhorling Monastery Ito Exemption Ward Vpo Chauntra Tehsil, Joginder Nagar, बनाम/ Vs. Solan (Hp) - 175032 Distt. Mandi (Hp) – 175032 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaaaz-0663-P (अपीलाथ"/Appellant) (""थ" / Respondent) : अपीलाथ"कीओरसे/ Appellant By : Sh. Parikshit Chauhan (Advocate) – Ld. Ar ""थ"कीओरसे/Respondent By : Sh. Dr. Ranjit Kaur (Addl. Cit) - Sr. Dr सुनवाईकीतारीख/Date Of Hearing : 03.02.2026 घोषणाकीतारीख /Date Of Pronouncement : 04.02.2026 आदेश / O R D E R

For Appellant: Sh. Parikshit Chauhan (Advocate) – Ld. ARFor Respondent: Sh. Dr. Ranjit Kaur (Addl. CIT) - Sr. DR
Section 143(3)

building and accordingly, capitalized in the books of accounts. The payee carried out the work of construction of the monastery building using the corpus donations which was received from the donors directly in the bank account of the payee. The entries were duly reflected in the books of the assessee

TEAM COLOURS FOUNDATION,VADLAMURU vs. ITO, EXEMPTION WARD, RAJAHMUNDRY

In the result, appeal of the assessee is allowed for statistical purpose

ITA 730/VIZ/2025[2023-24]Status: DisposedITAT Visakhapatnam30 Jan 2026AY 2023-24

Bench: Ld.CIT(A) and this First Appellate Authority confirmed the addition by stating that the Trust doesn't have Registration u/s 12AB and hence all the donations were taxable as corpus donations. For coming to this conclusion, the Ld.CIT(A) quoted several decisions in his appeal order including a Supreme Court decision of UP Forest Corporation Vs. CIT, 297 ITR 1 (SC). 5. The appellant Trust filed an appeal before ITAT with the grounds of appeal mentioned in para 2 of this order. Apart from argui

Section 11Section 12ASection 80G(5)

Appellate Authority confirmed the addition by stating that the Trust doesn’t have Registration u/s 12AB and hence all the donations were taxable as corpus donations. For coming to this conclusion, the Ld.CIT(A) quoted several decisions in his appeal order including a Supreme Court decision of UP Forest Corporation

SHREE TEKCHANDJI MAHARAJ TRUST,UJJAIN vs. ASSESSING OFFICER, UJJAIN

ITA 537/IND/2025[2016-17]Status: DisposedITAT Indore30 Jan 2026AY 2016-17
Section 133(6)Section 139(1)Section 142(1)Section 144Section 147Section 148Section 148ASection 250Section 253Section 69A

applicable.\n1. Certificate of Registration from Charity Commissioner.\n2. Details of any Amendments made in the Trust Deed since incorporation.\nDetails of Corpus & Non Corpus Donation Received during the year, if any, in the following\nformat:-\nName, Address & Amount\nPAN of Donor\nMode of Payment Nature\ninvolved ... reply\nhas been submitted before the assessment unit. A reply has been\nsubmitted along with all supporting evidences.\n7. The trust was receiving corpus donations for construction of\nDharamshala, evidences of all such corpus donation and trust\nregistration has been submitted. All cash deposits has been\nrecorded in books

VISHVA KALYAN FOUNDATION,SURENDRANAGAR vs. ITO WARD 2 EXEMPETION AHMEDABAD, AHMEDAABD

In the result, the appeal of the assessee is allowed

ITA 1992/AHD/2025[2020-21]Status: DisposedITAT Ahmedabad30 Jan 2026AY 2020-21

Bench: Shri Siddhartha Nautiyal & Smt. Annapurna Gupta

For Appellant: Shri Gaurang Khakhkhar, CAFor Respondent: Shri Rameshwar P Meena, SR-DR
Section 143(1)Section 154

appellate authority, exemption under sections 11 and 12 cannot be denied merely for such delay. The Tribunal also observed that treating issues such as corpus donation or denial of exemption on technical grounds while processing under section 143(1) travels beyond the permissible scope of prima facie adjustments contemplated

SHREE BILIMORA VIBHAG ANAVIL MANDAL NUTAN PARK, SHANTI NIKETAN SOCIETY MORORJI DESAI MARG BILIMORA NA vs. ARI,NAVSARIVS.CIT(EXEMPTION), SURAT

In the result, the appeal of the assesse is allowed for statistical purpose

ITA 11/SRT/2025[2015-16]Status: DisposedITAT Surat29 Jan 2026AY 2015-16

Bench: Dr. Dinesh Mohan Sinha & Shri Bijayananda Pruseth

For Appellant: Shri Sujesh C. Suratwala, CAFor Respondent: Shri Ajay Uke, Sr. DR
Section 11Section 143(1)Section 57

facts and circumstances of the case and in law, learned CPC Banglore has erred in treating corpus donation of Rs. 11,77,424/- as income of the assesse trust but as a matter of fact the same is in the nature of capital receipt and not covered within ambit ... facts and circumstances of the case and in law, learned CPC Banglore has erred in treating corpus donation of Rs. 11,77,424/- as income of the assesse trust but as a matter of fact the same is in the nature of capital receipt and not covered within ambit

SHREE BILIMORA VIBHAG ANAVIL MANDAL NUTAN PARK, SHANTI NIKETAN SOCIETY, MORARJI DESAI MARG BILIMORA NA vs. ARI,NAVSARIVS.CIT(EXEMPTION), SURAT

In the result, the appeal of the assesse is allowed for statistical purpose

ITA 10/SRT/2025[2014-15]Status: DisposedITAT Surat29 Jan 2026AY 2014-15

Bench: Dr. Dinesh Mohan Sinha & Shri Bijayananda Pruseth

For Appellant: Shri Sujesh C. Suratwala, CAFor Respondent: Shri Ajay Uke, Sr. DR
Section 11Section 143(1)Section 57

facts and circumstances of the case and in law, learned CPC Banglore has erred in treating corpus donation of Rs. 11,77,424/- as income of the assesse trust but as a matter of fact the same is in the nature of capital receipt and not covered within ambit ... facts and circumstances of the case and in law, learned CPC Banglore has erred in treating corpus donation of Rs. 11,77,424/- as income of the assesse trust but as a matter of fact the same is in the nature of capital receipt and not covered within ambit

THE FALAHE DARAIN EDUCATION SOCIETY,AHMEDABAD vs. DCIT, CIRCLE-1, EXMP., AHMEDABAD, AHMEDABAD

In the result, appeal filed by the assessee is allowed

ITA 2111/AHD/2025[2016-17]Status: DisposedITAT Ahmedabad27 Jan 2026AY 2016-17

Bench: SMT. ANNAPURNA GUPTA (Accountant Member), SHRI T.R. SENTHIL KUMAR (Judicial Member)

For Appellant: Shri Sunil Talati, A.RFor Respondent: Smt. Ananya Kulshresth, Sr.DR
Section 11(1)(d)Section 12ASection 250Section 69ASection 80G

erred in confirming the addition of Rs. 48,38,779/- by denying the exemption u/s 11(1)(d) towards corpus donations. The appellant had received genuine voluntary contributions wholly for its charitable objects, which were duly recorded in the audited books of account and supported by donor lists and records ... that there are primarily two issues involved in the present appeal relating to: (i) rejecting assessee’s claim of exemption on account of corpus donations received by it to the tune of Rs.48,38,779/- & (ii) making additions on account of cash deposited in bank accounts of the assessee

DCIT CIRCLE-1(1) (E), NEW DELHI vs. GURU GOBIND SINGH EDUCATIONAL CHARITABLE TRUST, NEW DELHI

In the result, appeal of the Revenue in ITA No

ITA 8504/DEL/2019[2015-16]Status: DisposedITAT Delhi21 Jan 2026AY 2015-16

Bench: Shri Yogesh Kumar Us & Shri Naveen Chandra

For Appellant: Shri Subodh Gupta, AdvFor Respondent: Shri Amit Jain, CIT- DR
Section 115BSection 12ASection 133(6)Section 68

that non- response of the donors does not explain the donations satisfactorily, the Assessing Officer held the receipts in the form of voluntary and corpus donations, from 12 parties, to be unexplained cash credits in the books of the assessee and added the same u/s 68 of the Act. Accordingly

DEPUTY COMMISSIONER OF INCOME TAX (EXEMPTIONS) , CHENNAI vs. THE ICICI FOUNDATION FOR INCLUSIVE GROWTH , MUMBAI

In the result, the appeal filed by the Revenue is dismissed

ITA 2386/CHNY/2025[2012-13]Status: DisposedITAT Chennai20 Jan 2026AY 2012-13

Bench: Hon’Ble Shri Manu Kumar Giri & Before Hon’Ble Shri Manu Kumar Giri & Before Hon’Ble Shri Manu Kumar Giri & Before Hon’Ble Shri Manu Kumar Giri & Shri S.R. Raghunathashri S.R. Raghunathashri S.R. Raghunathashri S.R. Raghunathaआयकर आयकर अपील आयकर आयकर अपील अपील संसंसंसं././././Ita No.2 अपील

For Appellant: Mr. S.Sriram, AdvocateFor Respondent: Ms. E.Pavuna Sundari, CIT
Section 11(1)(d)Section 12ASection 80G

charitable trust registered under section 12AA and also approved u/s.80G of the Income Tax Act, 1961. During the year under consideration, the assesseereceived corpus donations aggregating to Rs.26,10,59,858/- from ICICI Bank Ltd., ICICI Home Finance Ltd., ICICI Venture Fund Management Company Ltd. and IKP Knowledge Park ... Assessing Officer accepted that the receipts were corpus donations and were exempt u/s.11(1)(d) of the Act. However, he observed that the assessee had withdrawn an amount of Rs.19,34,72,836/- from the corpus fund to meet expenditure during the year. According to the Assessing Officer, the administrative

BLIND PEOPLES ASSOCIATION INDIA,AHMEDABAD vs. THE DY.CIT, CIRCLE-1(EXEMPTION), AHMEDABAD

In the result, the appeal of the assessee is allowed

ITA 1959/AHD/2025[2016-17]Status: DisposedITAT Ahmedabad07 Jan 2026AY 2016-17

Bench: Dr. Brr Kumar & Ms. Suchitra Kambleassessment Year 2016-17

For Appellant: Shri Nitin Pathak, A.RFor Respondent: Shri Amit Pratap Singh, Sr. D.R
Section 143(3)

view. If micro view is taken, then qua each receipt, certain donation could have been allowed. If macro view is taken, the facts remain corpus donation.” I.T.A No. 1959/Ahd/2025 Blind Peoples Association India, A.Y. 2016-17 3. The assessee trust filed its return of income on 22-09- 2016 declaring ... assessment order dated 11- 12-2018 was passed u/s. 143(3) of the Income Tax Act, 1961. Vide the said order, the claim of corpus donation in respect of the amount of Rs. 5,39,59,121/- made by the assessee in the return of income for the assessment year

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