“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

M/S. Seth Chagan Mall Hira Lall Dugar Charitable Trust, Kolkata vs. I.T.O., Ward - 1(3), Exemption, Kolkata

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

ITA 1358/KOL/2024[2019-2020]Status: DisposedITAT Kolkata16 Oct 2024AY 2019-2020

Bench: Sri Rajesh Kumar & Pradip Kumar Choubey

Section 11(2)(ii)Section 143Section 143(1)Section 250

submitting that the ld. AO as well as ld. CIT (Exemption) have erred in disallowing the application of the income and taxing the non-corpus donation received by the Trust while processing the return on the ground of non-furnishing of Form- 9A ignoring the fact that it was inadvertently

St.Joseph'S Educational Trust, Chennai vs. PCIT Central Chennai - 1, Chennai

In the result, all the three appeals filed by the assessee are allowed

ITA 1620/CHNY/2024[2020-21]Status: DisposedITAT Chennai15 Oct 2024AY 2020-21

Bench: Hon’Ble Shri Manu Kumar Giri & Hon’Ble Shri Jagadishआयकरअपील सं./ Ita Nos.1618 & 1619 /Chny/2024 (िनधा"रणवष" / Assessment Years: 2018-19 & 2020-2021) St. Joseph’S Institute Of Science & Vs. The Principal Commissioner Of Income Technology Trust, Tax, No.56C, Old Mahabalipuram Road, Central, Chennai -1 Sholinganallur, Chennai 600 119. [Pan: Aahts 9943B] आयकरअपील सं./ Ita No.1620 /Chny/2024 (िनधा"रणवष" / Assessment Year: 2020-2021) St. Joseph’S Educational Trust, Vs The Principal Commissioner Of Income No.56C, Old Mahabalipuram Road, Tax, Sholinganallur, Chennai 600 119. Central, Chennai -1 [Pan: Aamts 3888G] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/ Appellant By : Shri K.R. Vasudevan, Advocate ""यथ" क" ओर से /Respondent By : Shri Nilay Baran Som, Irs, Cit.

For Appellant: Shri K.R. Vasudevan, AdvocateFor Respondent: Shri Nilay Baran Som, IRS, CIT

Section 11Section 115BSection 12ASection 142(1)Section 153ASection 153DSection 263

alleged receipts are capitation fees. The assessees have also offered to tax those receipts in the form of DD, which were already recorded as "corpus donations" in the books of accounts were offered as "voluntary donations" in accordance with the provisions of section ... Educational Trust for the asst. year 2020-21 has been offered in the respective asst. year. 3. Please produce relevant receipts in connection with corpus donations claim of Rs.5,88,60,300/- for the asst. year 2018-19 and Rs.24,00,000/- for the asst. year 2020-21. Also, furnish

St.Joseph'S Institute of Science and Technology Trust, Chennai vs. PCIT Central Chennai - 1, Chennai

In the result, all the three appeals filed by the assessee are allowed

ITA 1619/CHNY/2024[2020-21]Status: DisposedITAT Chennai15 Oct 2024AY 2020-21

For Appellant: Shri K.R. Vasudevan, AdvocateFor Respondent: Shri Nilay Baran Som, IRS, CIT

Section 11Section 115BSection 12ASection 142(1)Section 153ASection 153DSection 263

St.Joseph'S Institute of Science and Technology Trust, Chennai vs. PCIT Central Chennai - 1, Chennai

In the result, all the three appeals filed by the assessee are allowed

ITA 1618/CHNY/2024[2018-19]Status: DisposedITAT Chennai15 Oct 2024AY 2018-19

Section 11Section 115BSection 12ASection 142(1)Section 153ASection 153DSection 263

alleged receipts are capitation fees. The assessees have also offered to tax those receipts in the form of DD, which were already recorded as "corpus donations' in the books of accounts were offered as "voluntary donations" in accordance with the provisions of section ... Educational Trust for the asst. year 2020-21 has been offered in the respective asst. year. 3. Please produce relevant receipts in connection with corpus donations claim of Rs.5,88,60,300/- for the asst. year 2018-19 and Rs.24,00,000/- for the asst. year 2020-21. Also, furnish

Asstt. Commissioner of Income Tax, Exemptions, Circle-2, Chandigarh vs. M.R.S. Shri Prannath Parnami Education Society, Haryana

In the result, the appeal is dismissed

ITA 253/CHANDI/2024[2017-18]Status: DisposedITAT Chandigarh14 Oct 2024AY 2017-18

Bench: Shri A.D. Jain & Shri Krinwant Sahayआयकर अपील सं./Ita No.253/Chd/2024 "नधा"रणवष" / Assessment Year : 2017-18 Asstt. Commissioner Of बनाम M.R.S. Shri Prannath Income Tax, Exemptions, Parnami Education Society, Circle-2, 20Km Stone, Chandigarh Rajgarh Road, Vpo Choudhariwas Hisar 125001 "थायीलेखासं./Pan No: Aabam1046N अपीलाथ"/Appellant ""यथ"/Respondent ( Hybrid Hearing ) "नधा"रतीक"ओरसे/Assessee By :Sh. Kapil Goyal, Advocate राज"वक"ओरसे/ Revenue By : Smt. Kusum Bansal, Cit, Dr सुनवाईक"तार"ख/Date Of Hearing : 19.09.2024 उदघोषणाक"तार"ख/Date Of Pronouncement : 14.10.2024 आदेश/Order Per A.D. Jain: This Is Assessee’S Appeal Against The Order Of The Ld. Cit(A), National Faceless Appeal Centre (Nfac), Delhi, Dated 14.01.2024, For The Assessment Year 2017-18, Taking The Following Grounds Of Appeal:

For Appellant: Sh. Kapil Goyal, AdvocateFor Respondent: Smt. Kusum Bansal, CIT, DR

Section 11(1)(d)Section 133(6)

erred in deleting the addition of Rs.3,35,42,110/- made by the A.O. by treating the amount shown to be received as corpus donation as voluntary donation received during the FY 2016-17 relevant to AY 2017-18 without considering the facts of the case. II. Whether on facts ... seen that there is no cogent material brought on record by the Assessing Officer to support his action in treating the amount of corpus donation received by the Assessee under specific directions. The A.O., as correctly observed by the ld. CIT(A), has not proved any other intent

Assistant Commissioner of Income Tax, Exemptions, Circle, Jaipur, Jaipur Rajasthan vs. Navratan Vidha Mandir Shiksha Samiti, Jaipur Rajasthan

In the result appeal filed by the Department is dismissed and the C

ITA 201/JPR/2024[2012-13]Status: DisposedITAT Jaipur27 Sept 2024AY 2012-13

Bench: SHRI SANDEEP GOSAIN (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri P.C.Parwal, CAFor Respondent: Shri Arvind Kumar, CIT-DR

Section 11Section 11(5)Section 13(1)(d)Section 145(3)

beating The amount of Rs 2,27,78,950/--on account of development fund as a revenue receipt instead of a corpus donation or a capital receipt. 7.1 I have considered the assessment order and the submissions of the appellants, The basic premise of the AO has been that ... parties except students. 3.4.2 Accordingly, it is a part of the fees. Therefore, the AO held that the same can’t be classified as corpus donation or contribution as the same is not voluntary and is not for any specified purpose. Accordingly, he considered development receipt of Rs.2

Giniya Devi Badangaria Charitable Trust, Jhunjhunu vs. CIT(E), Jaipur

In the result both the appeals of the assessee are allowed for statistical purposes as indicated hereinabove

ITA 792/JPR/2024[NA]Status: DisposedITAT Jaipur23 Sept 2024

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri P.C. Parwal (C.A.)For Respondent: Shri Ajey Malik (CIT)

Section 12ASection 12A(1)(ac)Section 80GSection 80G(5)

object and the genuineness of the activities is not proved Giniya Devi Badangaria Charitable Trust vs. CIT(E) inasmuch as receipt and confirmation of corpus donation is not furnished, payments are made in cash but cash withdrawal is not seen in the bank account except of Rs.10 ... contended that assessee has furnished the name, address, mobile no., PAN, date and amount of donation given by various persons and confirmation of such corpus donation was filed before us. It is further explained that expenditure incurred in cash under various heads are of petty amount which

Giniya Devi Badangaria Charitable Trust, Jhunjhunu vs. CIT(E), Jaipur

In the result both the appeals of the assessee are allowed for statistical purposes as indicated hereinabove

ITA 791/JPR/2024[NA]Status: DisposedITAT Jaipur23 Sept 2024

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri P.C. Parwal (C.A.)For Respondent: Shri Ajey Malik (CIT)

Section 12ASection 12A(1)(ac)Section 80GSection 80G(5)

Sree Raghavendra Educational Society, Chennai vs. ITO (Exemptions) Ward 4, Chennai

In the result, appeals filed by the assessee for both the assessment years are allowed for statistical purposes

ITA 835/CHNY/2024[2015-16]Status: DisposedITAT Chennai20 Sept 2024AY 2015-16

Bench: Shri Mahavir Singh, Hon’Ble & Shri S. R. Raghunatha, Hon’Bleआयकर अपील सं./Ita Nos.: 834 & 835/Chny/2024 िनधा"रण वष" / Assessment Years: 2011-12 & 2015-16

For Respondent: Shri. G. Suresh, JCIT

Section 11Section 12ASection 13(1)(C)Section 13(1)(c)Section 201Section 40

assessee by applying commercial principles, denying the assessee society exemption under section 11 of the Income Tax Act and consequently brought to tax the ‘corpus donations’ received by the assesses society by observing that the sum of Rs.1,97,32,100/- would fall under the definition of income and includable ... erred in treating ‘corpus :-8-: ITA. Nos: 834 & 835/Chny/2024 donations’ as income of the Trust without appreciating the fact that the ‘corpus donations’ forming part of corpus of the Trust, is capital receipt which cannot be included in the income of the Trust’. The assessee submits that

Sree Raghavendra Educational Society, Chennai vs. ITO (Exemptions) Ward 1, Chennai

In the result, appeals filed by the assessee for both the assessment years are allowed for statistical purposes

ITA 834/CHNY/2024[2011-12]Status: DisposedITAT Chennai20 Sept 2024AY 2011-12

Bench: Shri Mahavir Singh, Hon’Ble & Shri S. R. Raghunatha, Hon’Bleआयकर अपील सं./Ita Nos.: 834 & 835/Chny/2024 िनधा"रण वष" / Assessment Years: 2011-12 & 2015-16

For Respondent: Shri. G. Suresh, JCIT

Section 11Section 12ASection 13(1)(C)Section 13(1)(c)Section 201Section 40

Tirupur South Rotary Educational Trust, Tirupur vs. The ACIT, Exemtions, Coimbatore

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

ITA 1107/CHNY/2024[2022-23]Status: DisposedITAT Chennai18 Sept 2024AY 2022-23

Bench: Shri Aby T. Varkey & Shri Manoj Kumar Aggarwalआयकर अपील सं./Ita No.1107/Chny/2024 िनधा"रण वष"/Assessment Year: 2022-23 V. Tirupur South Rotary – The Acit (Exemptions), Educational Trust, Coimbatore. South Rotary Hall, Nataraj Theatre Road, Tirupur-641 604. [Pan: Aabtt 7879 H] (अपीलाथ"/Appellant) (""यथ"/Respondent)

For Appellant: Mr. S. Sridhar, Adv. (Erode)For Respondent: Ms. R. Anita, Addl.CIT

Section 11Section 11(5)Section 119(2)(b)Section 12ASection 12A(1)(b)Section 139(1)Section 143(1)Section 2(24)(iia)Section 44A

audited before due date. Therefore, the appellant cannot be allowed the benefit of section 11 which includes section 11(5). Therefore, the receipt through corpus donation is chargeable to tax as per the provision of section 2(24)(iia) and benefit of section 11 is not allowable. The case laws ... CBDT to condone the delay in filing of Form 10AB. We note that the Ld.CIT(A) has sustained addition which was the corpus-donation received by the assessee to the tune of Rs.99 lakhs, since the assessee didn’t file the Audit Report within the due date. Since the assessee

Dr. B.G. Memorial Trust, Kolkata vs. ITO, Ward-1(2), Exemption, Kolkata

The appeal of the assessee is treated as allowed for statistical purposes

ITA 680/KOL/2024[2013-14]Status: DisposedITAT Kolkata13 Sept 2024AY 2013-14

Bench: Shri Sanjay Garg & Shri Sanjay Awasthii.T.A. No.680/Kol/2024 Assessment Year: 2013-14 Dr. B. G. Memorial Trust..…….…....…………….......…....………....Appellant 6/1, Sarat Chatterjee Avenue Rabindra Sarovar, Kolkata – 700029. [Pan: Aaatd5235A] Vs. Ito, Ward-1(2), Exempt, Kolkata...........................................…..…..... Respondent Appearances By: Shri S. M. Surana, Ar & Sunil Surana, Ar, Appeared On Behalf Of The Appellant. Shri Manas Mondal, Addl. Cit, Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : June 27, 2024 Date Of Pronouncing The Order : September 13, 2024 आदेश / Order संजय गग", "या"यक सद"य "वारा / Per Sanjay Garg: The Present Appeal Has Been Preferred By The Assessee Against The Order Dated 18.03.2024 Of The National Faceless Appeal Centre [Hereinafter Referred To As ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’). 2. The Brief Facts Of The Case Are That The Assessee Was Registered As A Charitable Institution U/S 12 Of The Act. The Assessee Claimed Deduction Of Income Being A Charitable Institution U/S 11 Of The Act. During The Assessment Proceedings, The Assessing Officer Noted That The Cit(Exemption) Vide Order Dated 22.02.2016 U/S 12Aa(3) Of The Act Has Withdrawn & Cancelled Registration Granted Earlier To The Assessee-Trust. In View Of The Said Cancellation Of Registration, The

Section 11Section 12Section 12ASection 250Section 40Section 40A

Trust Assessing Officer denied the deduction of income to the assessee u/s 11 of the Act and further also found discrepancies in relation to corpus donation on account of unexplained increase in assets and disallowance u/s 40(a)(ia) etc. 3. The ld. CIT(A) confirmed the addition so made ... balance sheet. 5 For that the Ld CIT(A) erred in confirming the addition of an amount of Rs 1,25,42,308/- as corpus donations when the addition made by the AO was of the amount of Rs. 75,43,613/- and not Rs.1

Tamilnadu Industrial Guidance and Export Promotion Bureau, Chennai vs. ITO Exemptionas Ward-1, Chennai

In the result, both the appeals filed by the assessee are allowed for statistical purposes

ITA 1660/CHNY/2024[2014-15]Status: DisposedITAT Chennai11 Sept 2024AY 2014-15

Bench: Shri Mahavir Singhand Shri Amitabh Shuklaआयकर अपील सं./Ita Nos.:1659 & 1660/Chny/2024 िनधा"रण वष"/Assessment Years: 2013-14 & 2014-15 Tamil Nadu Industrial The Income Tax Officer, Guidance & Export Vs Exemptions Ward 1, Promotion Bureau, Chennai No.19-A, Rukmani Lakshmipathy Salai, Egmore, Chennai – 600 008. Pan: Aacct 7538B (""यथ"/Respondent) (अपीलाथ"/Appellant) अपीलाथ" क" ओर से/Appellant By : Shri M.V. Swaroop, Advocate ""यथ" क" ओर से/Respondent By : Shri Keerthi Narayanan, Jcit सुनवाई क" तारीख/Date Of Hearing : 05.09.2024 घोषणा क" तारीख/Date Of Pronouncement : 11.09.2024

For Appellant: Shri M.V. Swaroop, AdvocateFor Respondent: Shri Keerthi Narayanan, JCIT

Section 11Section 12ASection 143(3)Section 2(15)

since the amount of Rs.1,71,49,921/- is received as a fee for services rendered through single window system. The AO also added corpus donations of Rs.25,00,000/- and disallowed depreciation also. The AO treated these receipts as income by disallowing exemption claimed u/s.11 ... fresh adjudication. 8. The next common issue raised by the assessee in both the appeals is as regards to the addition of corpus donations. Since, we have remanded back the main issue of claim of exemption u/s.11 of the Act to the file of AO for fresh adjudication, this issue

Tamilnadu Industrial Guidance and Export Promotion Bureau, Chennai vs. ITO Exemptionas Ward-1, Chennai

In the result, both the appeals filed by the assessee are allowed for statistical purposes

ITA 1659/CHNY/2024[2013-14]Status: DisposedITAT Chennai11 Sept 2024AY 2013-14

For Appellant: Shri M.V. Swaroop, AdvocateFor Respondent: Shri Keerthi Narayanan, JCIT

Section 11Section 12ASection 143(3)Section 2(15)

Shri Rishabh Devji Kesarimaljijain Sh Mp Dt S Sangh, Ratlam vs. The Commissioner of Income Tax Appeal Addljcit(A)11 Mumbai, Mumbai

Appeal is allowed for statistical purpose

ITA 118/IND/2024[2019-20]Status: HeardITAT Indore06 Sept 2024AY 2019-20

Bench: Shri Vijay Pal Rao & Shri B.M. Biyaniassessment Year:2019-20 Shri Rishabh Devji Cpc Bengaluru/ Kesarimalji Jain Sh Mp Dt Cit(A)/Addl. Jcit-(A)-11, S. Sangh, Mumbai बनाम/ Bajaj Khana, Vs. Ratlam

Section 11Section 12ASection 139(4)Section 143(1)Section 2(45)Section 4

आयकर अपीलीय अिधकरण, इंदौर "ायपीठ, इंदौर IN THE INCOME TAX APPELLATE TRIBUNAL INDORE BENCH, INDORE BEFORE SHRI VIJAY PAL RAO

The M K Tata Trust, Mumbai vs. CIT (Exemptions), Mumbai

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

ITA 1743/MUM/2024[ 2016-17]Status: DisposedITAT Mumbai06 Sept 2024

Bench: Shri Amarjit Singh & Shri Raj Kumar Chauhan

For Appellant: Shri Vishal D Shah & Shri Jainam SonaiyaFor Respondent: Shri S. Srinivasu, CIT, DR

Section 11Section 11(5)Section 11(6)Section 13(1)(d)Section 143(3)Section 263

holds 2421 shares of Tata Sons Ltd which were settled by Late Shri M.K Tata in the Trust i.e. The MK Tata Trust as corpus donation in the year 1959. The trust has never utilized its receipts for making investment in shares of Tata Sons Limited. Further, Section ... been introduced w.e.f. 1.4.1983 and assessee had received shares as corpus donation in the year 1959 on settling the trust. Section 13 specifies certain cases to which section 11 shall not apply, section 13(1)(d) deals with investments which violate the provisions of Section 11(5). However there

The M K Tata Trust, Mumbai vs. CIT (Exemptions), Mumbai

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

ITA 1742/MUM/2024[2015-16]Status: DisposedITAT Mumbai06 Sept 2024AY 2015-16

Bench: Shri Amarjit Singh & Shri Raj Kumar Chauhan

For Appellant: Shri Vishal D Shah & Shri Jainam SonaiyaFor Respondent: Shri S. Srinivasu, CIT, DR

Section 11Section 11(5)Section 11(6)Section 13(1)(d)Section 143(3)Section 263

The Trained Nurses Association of India, New Delhi vs. DCIT Circle Exemption-2(1), New Delhi

In the result, the appeal of assessee is allowed

ITA 1002/DEL/2022[2017-18]Status: DisposedITAT Delhi05 Sept 2024AY 2017-18

Bench: Dr. B.R.R. Kumar & Sh. Sudhir Kumarassessment Year: 2017-18 The Trained Nurses Vs. Dcit Association Of India New Delhi L-17, Floreence Nightingale Lane, Green Park, New Delhi-110016 Pan No.Aaatt2930J (Appellant) (Respondent) Appellant By Ms. Rano Jain, Advocate Ms. Mansi Jain,Ca Respondent By Ms. Monika Dhami, Cit Dr Date Of Hearing: 02/09/2024 Date Of Pronouncement: 05/09/2024 Order Per Sudhir Kumar, Jm:

Section 11Section 12ASection 142(1)Section 143(3)Section 263

months, it has to be completed before March, 2017. Nowhere in the agreement it is mentioned as a tied up grant or as a corpus donation. 9. The Ld DR has submitted that the Ld CIT(Exemption) has given the reasons in the order how the prejudice has been caused

Sir Ratan Tata Trust, Mumbai Suburban vs. Additional /Joint/Deputy/Assistant Commissioner of Income Tax, NFAC, Mumbai

In the result, both the appeals of the assessee in both AY 2014-15 and AY

ITA 4156/MUM/2023[2018-19]Status: DisposedITAT Mumbai26 Aug 2024AY 2018-19

Bench: Ms Padmavathy S, Am & Shri Rahul Chaudhary, Jm

For Appellant: Shri P. J. Pardiwala a/wFor Respondent: Shri Sanyogita Nagpal, CIT-DR

Section 1Section 10(34)Section 11Section 11(5)Section 12ASection 13(1)(c)Section 13(1)(d)Section 13(2)(h)Section 2(15)

applicable. The ld. AR further submitted that the equity shares held by the assessee as on 31.03.2014 consists of corpus donations which was received in the year 1919 along with the acquisition till 01.06.1973 and that the accretion to the corpus donations are all in the form of bonus shares ... that the shares of Tata Sons Ltd., are not acquired as "investments" using the fund of the assessee Trust but received as corpus donations and on that count also section 13(1)(d) is not applicable. The ld AR also argued that the shares were received at the time

Sir Ratan Tata Trust, Mumbai Suburban vs. Deputy Commissioner of Income Tax (Exemption)-2(1), Mumbai

In the result, both the appeals of the assessee in both AY 2014-15 and AY

ITA 4154/MUM/2023[2014-15]Status: DisposedITAT Mumbai26 Aug 2024AY 2014-15

Bench: Ms Padmavathy S, Am & Shri Rahul Chaudhary, Jm

For Appellant: Shri P. J. Pardiwala a/wFor Respondent: Shri Sanyogita Nagpal, CIT-DR

Section 1Section 10(34)Section 11Section 11(5)Section 12ASection 13(1)(c)Section 13(1)(d)Section 13(2)(h)Section 2(15)