“corpus donation”

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

The decision most relied on for corpus donation is CIT v. Shri Plot Swetamber Murti Pujak Jain Mandal (211 ITR 293), cited in 204 judgments on BharatTax.

Leading authorities on corpus donation

CIT v. Shri Plot Swetamber Murti Pujak Jain Mandal

211 ITR 293 · 1995 · High Court

204

citing judgments

A charitable trust can carry forward its excess expenditure from previous years and adjust it against the income of subsequent years, which qualifies as an application of income under Section 11. Additionally, voluntary contributions received for a specific purpose are treated as corpus funds and are not taxable.

CIT v. Programme for Community Organisation

248 ITR 1 · 2001 · Supreme Court

citing judgments

The 15% exemption available to charitable trusts under Section 11(1)(a) is absolute and is not curtailed by the provisions of Section 11(2) regarding accumulation of income. Voluntary contributions received towards the corpus of a trust are excluded from the scope of income for Section 11(1)(a) exemption purposes.

CIT v. Programme for Community Organisation

228 ITR 620 · 1997 · High Court

citing judgments

For charitable or religious trusts, income for exemption under Sections 11 and 12 must be computed on a commercial basis, not head-wise as per Section 14, treating expenditure as a charge against income. The net income, along with non-corpus donations, forms the eligible base for determining the application of funds and the permissible accumulation under Section 11(1)(a).

P.M. Mohammed Meerakhan v. CIT

73 ITR 735 · 1969 · Supreme Court

citing judgments

The assessee bears the onus to prove the genuineness and voluntary nature of donations received, including corpus donations. Failure to discharge this burden allows the Assessing Officer to treat such donations as non-genuine or accommodation entries.

CIT v. Bijli Cotton Mills (P) Ltd.

116 ITR 60 · 1979 · Supreme Court

citing judgments

Dharmada collections are not taxable income of the assessee if they are genuinely meant for and spent on charitable purposes, or if they are voluntary contributions not accruing to the assessee's own benefit.

Director of Income Tax (Exemption) v. Keshav Social and Charitable Foundation

278 ITR 152 · 2005 · High Court

citing judgments

For charitable trusts claiming Section 11 exemption, Section 68 concerning cash credits does not apply to donations received. The non-submission or non-production of donor details does not automatically lead to an inference that the trust is introducing unaccounted money.

CIT v. National Association of Software & Services Companies

345 ITR 362 · 2012 · High Court

citing judgments

A one-time fee paid by members, with the understanding that it can only be used for capital purposes, is considered a corpus donation and is not taxable as income. This is especially true when separate fees are collected for services rendered.

DIT v. Shri Ramakrishna Seva Ashram

357 ITR 731 · 2013 · High Court

citing judgments

Donations made for a specific purpose are considered capital in nature and cannot be applied for charitable or religious purposes, thus not being deemed income from property for the purposes of Section 11 of the Income Tax Act.

Judgments citing corpus donation

Ragigudda Sri Prasanna Anjaneya Swamy Bhakta Mandali Trust, Bangalore vs. Income Tax Officer, Ward-2. (Exemption), Bangalore

In the result, appeals of the assessee for both the years are partly allowed for statistical purposes

ITA 1083/BANG/2023[2016-17]Status: DisposedITAT Bangalore14 Feb 2025AY 2016-17

Bench: Shri Laxmi Prasad Sahu & Shri Soundarajan K

For Appellant: Shri. Shreehari Kutsa, AdvocateFor Respondent: Shri. Subramanian, JCIT(DR)(ITAT), Bangalore

Section 11Section 11(1)(d)Section 11(2)Section 13Section 139(1)Section 234ASection 250

Appellant of NIL on the facts and circumstances of the case. 3. The learned Commissioner of Income-tax (Appeals) erred in law that corpus donation shall form part of the total income of the Trust whereas as per section 11(1)(d) of the act any donation with a specific

Ragigudda Sri Prasanna Anjaneya Swamy Bhakta Mandali Trust, Bangalore vs. Income Tax Officer, Ward-2. (Exemption), Bangalore

In the result, appeals of the assessee for both the years are partly allowed for statistical purposes

ITA 1082/BANG/2023[2015-16]Status: DisposedITAT Bangalore14 Feb 2025AY 2015-16

Bench: Shri Laxmi Prasad Sahu & Shri Soundarajan K

For Appellant: Shri. Shreehari Kutsa, AdvocateFor Respondent: Shri. Subramanian, JCIT(DR)(ITAT), Bangalore

Section 11Section 11(1)(d)Section 11(2)Section 13Section 139(1)Section 234ASection 250

Amala Cancer Hospital Society, Thrissur vs. ACIT(E), Kochi

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

ITA 33/COCH/2025[2012-13]Status: DisposedITAT Cochin13 Feb 2025AY 2012-13

Bench: Shri Inturi Rama Rao

For Appellant: Sri.C.J.Romid, CAFor Respondent: Smt.Leena Lal, Senior AR

Section 143(3)Section 282(1)

hereinafter) at a total income of 2 ITA No.33/Coch/2025. Amala Cancer Hospital Society. Rs.22,05,112. While doing so, the AO made addition of corpus donation of Rs.15,99,916 and determined the total income in a normal commercial manner. 3. Being aggrieved, an appeal was filed before

ACIT., Exemptions Circle-1(1), Hyderabad vs. Pharmaceuticals Export Promotion Council of India, Hyderabad

In the result, the appeal of Revenue is allowed

ITA 1199/HYD/2024[2016-17]Status: DisposedITAT Hyderabad11 Feb 2025AY 2016-17

Bench: Shri Laliet Kumar, Hon’Ble & Shri G. Manjunatha, Hon’Bleassessment Year: 2016-17 The Assistant Commissioner Vs. Pharmaceuticals Export Of Income Tax, Promotion Council Of India, Exemptions, Circle – 1(1), Hyderabad. Hyderabad. Pan : Aadcp4643C (Appellant) (Respondent) Assessee By: Shri Rv. Chalam, C.A. Revenue By: Shri B. Balakrishna, Cit-Dr Date Of Hearing: 10.02.2025 Date Of Pronouncement: 11.02.2025

For Appellant: Shri RV. Chalam, C.AFor Respondent: Shri B. Balakrishna, CIT-DR

Section 11Section 11(1)(a)Section 12(1)Section 12ASection 143(2)Section 143(3)Section 144

favour of the assessee and against the Revenue. 36. The only other substantial question of law which arises in this appeal relates to the corpus donation of `7,70,000/- received by the assessee. The finding of fact recorded by the Tribunal is that the members who paid ... spent by the assessee only for the purposes of acquiring a capital asset and, therefore, the amount must be held to be a corpus donation, not taxable as income. Since this is essentially a finding of fact no substantial question of law arises for our consideration. 37. We now take

Ramya Charitable Trust, Kakinada vs. Income Tax Officer, Exemption Ward, Rajahmundry

In the result, appeal of the assessee is partly allowed

ITA 61/VIZ/2024[2017-18]Status: DisposedITAT Visakhapatnam06 Feb 2025AY 2017-18

Bench: Shri K. Narasimha Chary, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपीलसं./I.T.A.No.61/Viz/2024 (निर्धारण वर्ा/ Assessment Year: 2017-18) Ramya Charitable Trust V. Ito (Exemption Ward) D.No. 9-11-130 Income Tax Office Elvinpeta, Kakinada – 533004 Aayakar Bhavan Andhra Pradesh Veerabhadrapuram Rajahmundry – 533105 [Pan: Aactr4315H] Andhra Pradesh (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent)

Section 11Section 12ASection 133(6)Section 142(1)Section 144

submitted that the ledger account demonstrates the accounting of donations, has been submitted before Ld.CIT(A). Further he also submitted that the Trust received corpus donation from its Managing Trustee amounting to Rs. 20 lakhs. He further submitted that the assessee has constructed a building costing ... corpus donation of Rs. 20,00,000/- from the Managing Trustee was utilised in the construction of the building in addition to the loan availed from Tata Capital. He therefore pleaded that this corpus donations cannot be treated as the income of the assessee. Further with respect to donation

Sardar Vallabh Bhai Patel Sansthan Trust, Bhopal vs. CIT Exemption, Bhopal

The appeal is allowed for statistical purpose

ITA 882/IND/2024[NA]Status: DisposedITAT Indore31 Jan 2025

Bench: Shri B.M. Biyani & Shri Udayan Das Guptaassessment Year:Na Sardar Vallabh Bhai Patel Cit (Exemption) Sansthan Trust Bhopal 22 Vasundhara Colony बनाम/ Behind Bank Colony Vs. Jahangirabad Bhopal (Assessee/Appellant) (Revenue/Respondent) Pan: Aarts6174N Assessee By Shri Ashish Goyal & N.D. Patwa, Ars Revenue By Shri Ram Kumar Yadav, Cit-Dr Date Of Hearing 28.01.2025 Date Of Pronouncement 31.01.2025

Section 12ASection 13(1)(b)

given to Kurmi students which includes more than 300 sub-castes. Further, the assessee was asked to submit the relevant directions letters for corpus donation received during the F.Y.2021- 22 and the assessee submitted vide its reply dated 29.02.2024 that the same will be submitted within the 7 days. However ... submission and considered the materials on record. We find that the assessee was asked to submit the relevant documents and letters, as proof of corpus donation received during the F.Y.2021-22 and the assessee prayed for 7 days time vide its reply dated 29.02.2024. However, Ld. CIT(E) rejected the application

Shri Ujjwal Gorakshan Sanstha, Nashik vs. C.I.T (Exemption), Pune

In the result, the appeal of the assessee is allowed

ITA 2015/PUN/2024[2024-25]Status: DisposedITAT Pune29 Jan 2025AY 2024-25

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.2015/Pun/2024 Assessment Year : 2024-25 Shri Ujjwal Gorakshan Sanstha, Vs. The Cit(Exemption), 1, 10 Vyapar Bhavan, Pune Pimpalgaon Baswant, Niphad, Dist. Nashik-422209 Maharashtra Pan : Aagts8879K Appellant Respondent

For Appellant: Shri Abhay AvachatFor Respondent: Shri Ajay Kumar Keshari

Section 11(1)(d)Section 12ASection 12A(1)(ac)

failed to produce any material/ documents to support its contention. 5. Regarding expenses on the objects and the copies of directions from donors of corpus donations, the assessee has stated that expenses on cattle feed/ medicines etc are done from 'Gorakshan Kalyan Fund'. The donations received from donors are directly

Sant Shankar Maharaj Aashram, Amravati vs. DCIT ACIT Cir-Exemp, Nagpur

In the result, appeal by the assessee is allowed

ITA 556/NAG/2024[2022-23]Status: DisposedITAT Nagpur28 Jan 2025AY 2022-23

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

For Appellant: Shri Mahavir AtalFor Respondent: Shri Sandipkumar Salunke

Section 11Section 11ASection 12ASection 143(1)Section 143(1)(a)Section 80GSection 80G(5)(vi)

should not be more than Voluntary Contribution other than corpus. Aggregate of income and amount of corpus donation not 2. Part–B eligible for exemption. Hence, exemption in excess of voluntary contribution other than corpus. Aggregate of income and amount of corpus donation not eligible for exemption

Udaya Provincial, Thrissur vs. ACIT(Exemption), Kochi

In the result, the appeal filed by the assessee stands partly allowed

ITA 675/COCH/2024[2017-18]Status: DisposedITAT Cochin22 Jan 2025AY 2017-18

Bench: Shri Inturi Rama Rao, Am Assessment Year: 2017-18 Udaya Provincial House .......... Appellant 01, Thrissur Road, Irinjalakuda Thrissur 680125 [Pan: Aabfu8995K] Vs. Asst. Commissioner Of Income Tax .......... Respondent (Exemption Circle), Kochi Appellant By: Ms. Niveditha Kammath, Advocate Respondent By: Smt. Leena Lal, Sr. D.R. Date Of Hearing: 17.01.2025 Date Of Pronouncement: 22.01.2025

For Appellant: Ms. Niveditha Kammath, AdvocateFor Respondent: Smt. Leena Lal, Sr. D.R

Section 11Section 12ASection 13(1)(c)Section 143(3)

While doing so, the AO brought to tax a sum of Rs. 13,77,682/- being the amount of foreign contribution treating as non-corpus donation holding to be revenue income. The AO also denied exemption u/s. 11 of the Act on the ground that the appellant violated the condition

Income Tax Officer, Chennai vs. Shri Shirdi Saibaba Spiritual and Charitable Trust, Chennai

In the result, the appeal stand dismissed

ITA 1777/CHNY/2024[2013-14]Status: DisposedITAT Chennai22 Jan 2025AY 2013-14

Bench: Hon’Ble Shri George George K, Vp & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकरअपील सं./ Ita No.1777/Chny/2024 (िनधा"रण वष" / Assessment Year: 2013-14) Ito (Exemptions) Shri Shirdi Saibaba Spiritual & बनाम/ Charitable Trust Ward-3, Chennai. # 17, 2Nd Floor, Sai Business Point, Mount Vs. Road, Saidapet, Chennai-600 015. "थायीलेखासं./जीआइआरसं./Pan/Tan No. Aaats-3448-J (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Shri Vinod D. Mudaliar (Jcit) -Ld. Dr ""थ"कीओरसे/Respondent By : Shri Debendra Narayan Kar (Advocate) – Ld. Ar सुनवाईकीतारीख/Date Of Hearing : 13-01-2025 घोषणाकीतारीख /Date Of Pronouncement : 22-01-2025 आदेश / O R D E R

For Appellant: Shri Vinod D. Mudaliar (JCIT) -Ld. DRFor Respondent: Shri Debendra Narayan Kar (Advocate)

Section 11Section 12ASection 143(3)Section 2(15)Section 80G(5)(vi)

religious purposes, the surplus so earned by the assessee would not be eligible for exemption u/s 11. The surplus earned by the assessee and corpus donation received by it was computed at Rs.301.47 Lacs which was to be brought to tax. 3.2 In the alternative, it was noted ... comes under the purview of first proviso to Sec. 2(15). 3.3 Finally, the assessee was denied exemption u/s 11 and its surplus including corpus donation was brought to tax and depreciation claim was granted against the same. Appellate Proceedings 4.1 The assessee stated that the main charitable activities

Salzer Educational Medical Research Trust, Coimbatore vs. ACIT, Exemptions, Coimbatore

The appeal stand allowed in terms of our above order

ITA 2334/CHNY/2024[2018-19]Status: DisposedITAT Chennai09 Jan 2025AY 2018-19

Bench: Hon’Ble Shri Manoj Kumar Aggarwal, Am & Hon’Ble Shri Manu Kumar Giri, Jm आयकरअपील सं./ Ita No.2334/Chny/2024 (िनधा)रण वष) / Assessment Year: 2018-19) Salzer Educational Medical Acit (Exemption) बनाम Research Trust Coimbatore. 9/175-A, Railway Station Road, / Vs. P.N. Palayam, Coimbatore-641 020. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aadts-4099-L (अपीलाथ"/Appellant) : (" थ" / Respondent) अपीलाथ" कीओरसे/ Appellant By : Shri S. Sridhar (Erode) (Advocate)- Ld.Ar " थ"कीओरसे/Respondent By : Ms. D. Komali Krishna (Cit) - Ld. Dr सुनवाई की तारीख/Date Of Hearing : 18-12-2024 घोषणा की तारीख /Date Of Pronouncement : 09-01-2025 आदेश / O R D E R Manoj Kumar Aggarwal ()

For Appellant: Shri S. Sridhar (Erode) (Advocate)- Ld.ARFor Respondent: Ms. D. Komali Krishna (CIT) - Ld. DR

Section 11Section 143(3)

presented to the bankers. Another argument is that the assessee has not able to substantiate that the recipient had not treated the same as corpus donation. However, no such doubt has been raised by Ld. AR. The only reason to deny the benefit is that the cheques have been encashed

Sandeep Mohanraj Singhi, Ahmedabad vs. ACIT, Circle4(2), Ahmedabad

In the result, appeal of the assessee is partly allowed

ITA 769/AHD/2024[2015-16]Status: DisposedITAT Ahmedabad07 Jan 2025AY 2015-16

Bench: Shri T.R. Senthil Kumar & Shri Narendra Prasad Sinhaassessment Year: 2018-19

Section 11Section 12ASection 143(3)Section 147Section 68

registered under Section 12AA of the Act. The assessee had received 80,00,000 numbers of equity shares of e-Infochips Limited as corpus donation from its trustee Shri Pratul Krishnakant Shroff on 12.12.2017. Thereafter, all the shares of e-Infochips Limited, including those held by the assessee, were acquired ... modes prescribed for availing exemption by investing net sale consideration into fixed deposits with a scheduled bank. (v) The receipt of the corpus donation was shown in the audited Balance Sheet of the assessee. The gain on sale of said equity shares was also shown in the audited Income & Expenditure

R K Sipani Foundation, Bangalore vs. Income Tax Officer (E), Ward-2, Bangalore

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

ITA 1910/BANG/2024[2013-14]Status: DisposedITAT Bangalore06 Jan 2025AY 2013-14

Bench: Shri Waseem Ahmed & Shri Soundararajan K.Assessment Year : 2013-14

For Appellant: Shri Suresh Muthukrishnan, CA

Section 11Section 12ASection 143(2)Section 234

different assessee altogether. 4. The authorities below are not justified in adding a sum of INR. 3,88,87,980/- being the Corpus Donations received by the Appellant trust under the facts and in the circumstances of the Appellant's case. 5. The authorities below are not justified in disallowing

Kamal Clearing and Forwarding Agency Private Limited, Mumbai vs. Income Tax Officer, Ward 6(3)(3), Mumbai

ITA 1575/MUM/2024[2011-12]Status: DisposedITAT Mumbai02 Jan 2025AY 2011-12

Bench: MS. KAVITHA RAJAGOPAL (Judicial Member), SHRI OMKARESHWAR CHIDARA ( (Accountant Member)

For Appellant: Shri Vipul ShahFor Respondent: Smt. Kavita P. Kaushik

Section 10Section 11(6)Section 143(3)Section 250Section 263

without appreciating the facts and submissions of the Appellant that the capital assets, on which depreciation was claimed, were purchased out of corpus donation of the trust and not from the recurring income of the fund and the claim of depreciation was fully allowable. 2. On the facts and circumstances ... behalf of the Assessee that the investments in the fixed assets in respect of which depreciation was claimed was made out of the corpus donations. Without prejudice to the aforesaid, by placing reliance upon the judgment of Hon’ble Supreme Court in the case of Commissioner of Income

Grene Robotics India Private Limited, Hyderabad vs. ITO., Ward-2(2), Hyderabad

In the result, the appeal is allowed for statistical purposes

ITA 152/HYD/2024[2015-16]Status: DisposedITAT Hyderabad02 Jan 2025AY 2015-16

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.152/Hyd/2025 (निर्धारण वर्ा/Assessment Year:2020-21) M/S. Nnf State Chapter Telangana, Income Tax Officer Vs. Hyderabad. (Exemptions), Pan: Aaean1771C Ward-1(2), Hyderabad. (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Shri M.V. Anil Kumar, C.A. रधजस् व द्वधरध/Revenue By: Ms. G. Saratha, Sr-Dr सुिवधई की तधरीख/Date Of Hearing: 16/07/2025 घोर्णध की तधरीख/Pronouncement: 18/07/2025 आदेश/Order Per Madhusudan Sawdia, A.M. : This Appeal Is Filed By M/S. Nnf State Chapter Telangana (“The Assessee”), Feeling Aggrieved By The Order Passed By The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi (“Ld. Cit(A)”), Dated 20.11.2024 For The A.Y. 2020-21. 2. The Assessee Has Raised The Following Grounds Of Appeal :

For Appellant: Shri M.V. Anil Kumar, C.AFor Respondent: Ms. G. Saratha, SR-DR

Section 11Section 143(2)Section 143(3)Section 144B

Section 143(3) read with Section 144B of the Act on 20.09.2022, making the additions of Rs.21,51,000/- on account of disallowance of corpus donations and Rs.20,90,339/- on account of disallowance of expenses held as provision. Accordingly, the Ld. AO assessed the total income at Rs.42 ... Authorised Representative (Ld. AR) submitted that, the assessee is in appeal on two issues i.e. (i) additions of Rs.21,51,000/- on account of corpus donations and (ii) addition of Rs.20,90,339/- on account of disallowance of expenses held as provision. On the issue of corpus donations

ACIT-3(3)(1), Mumbai vs. Sikka Ports and Terminals Limited, Mumbai

Accordingly the grounds raised by the revenue contending these two issues are dismissed

ITA 3047/MUM/2024[2018-19]Status: DisposedITAT Mumbai30 Dec 2024AY 2018-19

Bench: Shri Amit Shukla, Jm & Ms Padmavathy S, Am

For Appellant: Shri Nimesh Vora & MokshaFor Respondent: Shri Dr. Kishor Dhule, CIT-DR

Section 115JSection 135Section 14ASection 37Section 37(1)Section 80G

contribution made by a company toward the discharge of it's CSR to a registered charitable institution, in our view, is akin to corpus donations. Section 11(1)(d) of the Income Tax Act speaks of the specific or corpus, donations, although it has not been defined under Income ... Corpus donations are Sikka Ports and Terminals Ltd. donations wherein, the donor makes the donations to the donee for a specific purpose or object. Prior to the amendment made by amended CSR Rules of 2021, Rule 7 of the erstwhile CSR Rules permitted corpus contributions to charitable institutions as eligible

DCIT 3(3)(1), Mumbai vs. Sikka Ports and Terminal Limited, Mumbai

Accordingly the grounds raised by the revenue contending these two issues are dismissed

ITA 3755/MUM/2023[2020-21]Status: DisposedITAT Mumbai30 Dec 2024AY 2020-21

Bench: Shri Amit Shukla, Jm & Ms Padmavathy S, Am

For Appellant: Shri Nimesh Vora & MokshaFor Respondent: Shri Dr. Kishor Dhule, CIT-DR

Section 115JSection 135Section 14ASection 37Section 37(1)Section 80G

M R Educational and Social Trust, Chennai vs. ITO, Exemptions Ward-4, Chennai

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

ITA 2680/CHNY/2024[2018-19]Status: DisposedITAT Chennai20 Dec 2024AY 2018-19

Bench: Shri George George K & Shri Jagadishआयकर अपील सं./Ita No.2680/Chny/2024 िनधा"रण वष" /Assessment Year: 2018-19

For Appellant: Shri G. Tarun, AdvocateFor Respondent: Ms. Anitha, Addl. CIT

Section 143(3)

after making enquiry through verification unit noted that only 16 donors have furnished or uploaded their reply . The A.O therefore, made the addition on corpus donation of Rs. 1,28,35,000/- in respect of donors who have not been replied . Aggrieved, the assessee filed an appeal before ... authorities. 5. We have heard the rival submissions, and perused the materials available on record. The A.O has made the addition in respect of corpus donation only on the ground that some of donors have not replied in response to notices issued by the verification unit

Indian Society for Technical Education, New Delhi vs. ITO Exemption Ward 1(2), New Delhi

In the result, appeal filed by the assessee is allowed

ITA 1528/DEL/2024[2017-18]Status: DisposedITAT Delhi18 Dec 2024AY 2017-18

Bench: Shri S. Rifaur Rahman & Shri Yogesh Kumar Us, Judicialmember (Assessment Year : 2017-18

For Appellant: Shri Sanjay Agarwal, CAFor Respondent: Shri Om Parkash, Sr. DR

Section 11(1)(d)Section 12ASection 143(3)Section 250Section 80G(5)(vi)

during the year under consideration. The 5 India Society for Technical Education assessee has treated the above said membership fee as part of corpus donation whereas the Assessing Officer in the absence of specific directions from the donors treated the same as revenue receipt. This issue was considered

Gujarat Rajput Hitwardhak Mandal, Bharuch vs. Income Tax Officer, Ward-Exemption, Vadodara

In the result, the appeal filed by the Assessee is allowed for statistical purpose

ITA 1469/AHD/2024[2016-17]Status: DisposedITAT Ahmedabad29 Nov 2024AY 2016-17

Bench: Shri T.R. Senthil Kumar (Judicial Member), Shri Narendra Prasad Sinha (Accountant Member)

Section 11(1)(a)Section 11(1)(d)Section 11ASection 12ASection 271(1)(c)

assessee Trust has reduced exemption u/s. 11(1)(d) of the Act to Rs. NIL by showing Rs. 19,16,494/- as non-corpus donation and Rs. 1,08,46,340/- as exempt agricultural income. Since the assesse made wrong claim u/s. 11(1)(d), penalty proceedings