“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

Income Tax Officer(E) Ward- 2(4), New Delhi, Civic Centre New Delhi vs. Prakash Sewa Trust, Paschim Vihar

ITA 4305/DEL/2024[2016-17]Status: DisposedITAT Delhi07 Jan 2026AY 2016-17

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwal

Section 11Section 12ASection 143(3)

recipient trust of donation of Rs. 50,00,000/- i.e., Sangneria Foundation for Health and Education has received also received similar corpus donation from Pradeep Jindal Group of entry operation with the allegation that the unaccounted money of the beneficiary is routed through the entries of donation. It is well ... Department, Sangneria Foundation for Health and Education to whom the assessee has given Rs. 50,00,000 on 10.09.2015 had received similar corpus donations from Pradeep Jindal Group of Entry Operators', with the allegation that the unaccounted money of the beneficiary is routed though the entries of donations. In other

Jm Financial Foundation, Mumbai vs. ITO (Exemption)-Ward-1(4), Mumbai

In the result, appeal filed by assessee stands at for statistical purposes

ITA 6558/MUM/2025[2018-19]Status: DisposedITAT Mumbai29 Dec 2025AY 2018-19

Bench: Smt. Beena Pillai () & Shri Makarand Vasant Mahadeokar ()

Section 11Section 11(2)Section 147Section 148Section 151A

funds were given in accordance with the 2 I.T.A. No. 6557/Mum/2025 requirements of Companies Act, 2013 and said funds are in the nature of corpus donation provided by the Donors with specific directions regarding its utilisation and were thus not voluntary in nature and it did not have the character ... without appreciating that said funds were given in accordance with the requirements of Companies Act, 2013 and said funds are in the nature of corpus donation provided by the Donors with specific directions regarding its utilisation and were thus not voluntary in nature and it did not have the character

Jm Financial Foundation, Mumbai vs. ITO (Exem) Ward 1(4), Mumbai

In the result, appeal filed by assessee stands at for statistical purposes

ITA 6557/MUM/2025[2017-18]Status: DisposedITAT Mumbai29 Dec 2025AY 2017-18

Bench: Smt. Beena Pillai () & Shri Makarand Vasant Mahadeokar ()

Section 11Section 11(2)Section 147Section 148Section 151A

Kinkini, Bhilwara vs. ITO Exemption Ward 1, Jaipur

In the result, the appeal of the assessee is allowed

ITA 1185/JPR/2025[2023-24]Status: DisposedITAT Jaipur24 Dec 2025AY 2023-24

Bench: SMT. ANNAPURNA GUPTA (Accountant Member)

For Appellant: Sh.Mahendra Gargieya, AdvocateFor Respondent: Sh. Gautam Singh Choudhary

Section 11Section 11(1)Section 12ASection 143Section 143(1)Section 143(1)(a)Section 234BSection 250

account of the above reasons, the assessee was not eligible for grant of exemption under Sections 11 & 12 of the Act, and hence the corpus donation was liable to be taxed as income in the hands of the assessee. In response, the Counsel for the assessee submitted before us that ... income, it was specifically submitted that such amount of Rs. 17,96,000/- received by the assessee was a voluntary donation and not a corpus donation. Secondly, since the income of the assessee, as per the Profit & Loss account, was below the taxable limit, the assessee trust was not under

Deputy Commissioner of Income Tax (Exemption)-1(1), Mumbai vs. All India Gem and Jewellery Domestic Council, Mumbai

In the result, the appeal of the Revenue is dismissed

ITA 4652/MUM/2025[2015-16]Status: DisposedITAT Mumbai24 Dec 2025AY 2015-16

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan () Assessment Year: 2015-16

For Respondent: Mr. Firoz Andhyarujina

Section 11Section 2(15)

deleting the addition of H 1,60,30,000/- made by the Assessing made by the Assessing Officer on account of corpus donation claimed by the assessee Officer on account of corpus donation claimed by the assessee Officer on account of corpus donation claimed by the assessee as the assessee ... violation appreciate that if the tru leses exemption u/s 11 due to violation of proviso to section 2(15), then ever corpus donations of proviso to section 2(15), then ever corpus donations of proviso to section 2(15), then ever corpus donations cannot be excluded. excluded. 2. Briefly stated

Assistant Commissioner of Income Tax (Exemption) Circle-1, Bengaluru vs. Cosmopolis Educational Trust, Bengaluru

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

ITA 575/BANG/2023[2021-22]Status: DisposedITAT Bangalore18 Dec 2025AY 2021-22

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year: 2021-22

For Appellant: Shri Madhusudhan UA, AdvocateFor Respondent: Shri Shivanand H Kalakeri, CIT

Section 11

account of following receipts: (i) Receipt from main object Rs. 4,16,56,385/- (ii) Interest income Rs. 2,38,786/- (iii) Corpus Donation Rs. 50,60,49,193/- 8. The return of the assessee was selected for scrutiny under the CASS on account of large corpus donation. During ... nature and sources of receipts and application of the receipts towards the object. 9. The assessee explained that during the year it received corpus donation of Rs. 41,85,16,746/- only from M/s CET but the due to inadvertent error the corpus donation was shown

Shree Krishna Janmashtmi Mahotsav Samiti, Delhi vs. Income Tax Officer Exemption Ward 2(1), Delhi

The appeal is allowed

ITA 2198/DEL/2025[2014-15]Status: DisposedITAT Delhi17 Dec 2025AY 2014-15

Bench: Shri Anubhav Sharma & Shri Manish Agarwalshri Krishna Janmashtmi Vs. Income Tax Officer, Mahotsav Samiti Exemption, Ward 2(1) G4 Goenka Apartment, Civic Centre, Minto Road 19/41 Punjabi Bagh New Delhi – 110002 Delhi – 110026 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aaeas0987K Appellant .. Respondent

For Appellant: Sh. Nitin Gulati, AdvFor Respondent: Sh. Jitender Singh, CIT, DR

Section 11Section 12ASection 133(6)Section 143(3)Section 271(1)(c)Section 80G

appellant trust was in receipt of certain donation which according to the assessee was regular donation. However the Assessing Officer (AO) presumed to be Corpus Donation and issued notice u/s 133(6) of the I.T Act to the person who have given donation in the appellant trust Therefore I find

Apna Jahan Charitable Trust, New Delhi vs. ITO, Ward- Exemption 1(1), Delhi

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

ITA 5574/DEL/2024[-]Status: DisposedITAT Delhi15 Dec 2025

Bench: Shri C. N. Prasad & Shri M. Balaganesh

For Appellant: Shri Ahilesh Kumar, AdvFor Respondent: Shri Amit Jain, CIT DR

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

12AB(4) of the Act thereby making the assessee trust ineligible for registration. Further, the ld CIT(E) noticed that the assessee has received corpus donation of Rs. 25,05,000/-, which was stated to be received from the trustee Nitu Malik and Jaya Singh. The ld CIT(E) observed ... complete bank statement, bank book and cash book for such 3 years and till 31.03.2023. The assessee furnished the details of donation along with corpus donation giving the details of name, address, PAN of the donor for the last 3 years and till 31.03.2023. The assessee furnished the identity proof

Apna Jahan Charitable Trust, Delhi vs. CIT Exemption, Delhi

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

ITA 5491/DEL/2024[-]Status: DisposedITAT Delhi15 Dec 2025

Bench: Shri C. N. Prasad & Shri M. Balaganesh

For Appellant: Shri Ahilesh Kumar, AdvFor Respondent: Shri Amit Jain, CIT DR

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

Shri Multanchand Bora Trust, Pune vs. ACIT, Exemption, Circle- Aurangabad, Aurangabad

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

ITA 1312/PUN/2025[2020-21]Status: DisposedITAT Pune09 Dec 2025AY 2020-21

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita No.1312/Pun/2025 निर्धारण वषा / Assessment Year: 2020-21 Shri Multanchand Bora Trust, V The Assistant/Deputy 132B/2A, Ganeshkhind Road, S. Commissioner Of Income Pune – 411007. Tax, Exemption Circle, Aurangabad. Pan: Aafts3329F Appellant/ Assessee Respondent / Revenue Assessee By Shri Shrenik Gandhi Revenue By Shri Amit Bobde –Cit(Dr) Date Of Hearing 11/09/2025 Date Of Pronouncement 09/12/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Appeal Is Filed By The Assessee Against The Order Of Ld.Commissioner Of Income Tax(Exemption), Pune At Nashik Passed Under Section 263 Of The Income Tax Act, 1961 For A.Y.2020-21, Dated 30.03.2025 Emanating From Assessment Order U/S.143(3) Of The I.T.Act, Dated 20.09.2022. The Assessee Has Raised Following Grounds Of Appeal : “1. Ground No. 1: The Learned Cit (Exemption) Seriously Erred On The Facts & Law, In Exercising The Revisionary Powers Under Section

Section 143(3)Section 263Section 80G

that ld.CIT(Exemption) has recorded this fact in the order. Thus, the main allegation of the ITA No.1312/PUN/2025 [A] ld.CIT(Exemption) that donations were corpus donations is factually incorrect also this issue was verified by Assessing Officer. 4. Ld.Authorised Representative(ld.AR) for the Assessee took us through the details ... Assessing Officer has failed to verify 6 ITA No.1312/PUN/2025 [A] whether the donations made to Amar Prerana Trust and Bhausaheb Firodia Vriddhashram Sanstha were Corpus Donation or Revenue Expenditure! Ld.CIT(Exemption) has also stated that AO has not verified activity of Donee Trusts and not made any inquiry to verify

Vimalarjun Trust, Lucknow vs. ACIT, Central Circle-2, Delhi

In the result, the appeal of assessee is allowed

ITA 2094/DEL/2024[2017-18]Status: DisposedITAT Delhi05 Dec 2025AY 2017-18

Bench: Shri S Rifaur Rahman & Shri Vimal Kumarassessment Year 2017-18 Vimalarjun Trust, Vs. Acit, 2/652, Vikram Khand, Gomti Circle-2, Nagar, Lucknow Delhi Uttar Pradesh Pin: 226010 Pan No. Aabtv7815R (Appellant) (Respondent)

For Appellant: Shri Ved Jain, Advs. & Shri PawanFor Respondent: Shri Sanjay Kaushal, CIT DR

Section 133ASection 139Section 142(1)Section 143(1)Section 143(2)Section 153Section 153CSection 250

erred both on facts and in law in confirming the addition of Rs. 55,00,000/- made by the AO on account of corpus donation under section 68 read with section 115BBE of the Income Tax Act. (ii) That the abovesaid addition has been confirmed rejecting the detailed submissions

ACIT, Exemptions, Circle-1, Ahmedabad vs. Vyakti Vikas Kendra India, Ahmedabad

In the result, the appeal of the Revenue is dismissed

ITA 1656/AHD/2025[2016-17]Status: DisposedITAT Ahmedabad02 Dec 2025AY 2016-17

Bench: Ms. Suchitra Kamble & Shri Narendra Prasad Sinhaassessment Year: 2016-17

Section 10(23)(iiiad)Section 11Section 11(1)(a)Section 11(1)(d)Section 11(2)Section 143(3)Section 2(15)

circumstances of the case, the Ld. CIT(A), NFAC is justified in deleting the addition of Rs.24,90,54,752/- on account of corpus donation holding that the assessee is eligible for exemption u/s.11(1)(d) of the Act as the assessee not covered by proviso to section ... ground taken by the Revenue is dismissed. 11. Ground no.3 pertains to the addition of Rs.24,90,54,752/- on account of corpus donation which was claimed as exempt under section 11(1)(d) of the Act. This issue is also covered by the decision of the Tribunal in assessee

Assistant Commissioner of Income Tax (E), Lucknow vs. M/S. Indian Institute of Carpet Technology, Bhadohi

In the result, the appeal of the Revenue is dismissed

ITA 117/LKW/2020[2016-17]Status: DisposedITAT Lucknow28 Nov 2025AY 2016-17

Bench: Sh. Kul Bharat & Sh. Nikhil Choudharya.Y. 2016-17 Asstt. Commissioner Of Vs. M/S Indian Institute Of Carpet Income-Tax (Exemption), Technology, Chauri Road, Srn, Lucknow Bhadohi Pan: Aaaji0124M (Appellant) (Respondent) Assessee By: Sh. Akash Agrawal, C.A. Revenue By: Sh. Amit Kumar, Dr Date Of Hearing: 10.09.2025 Date Of Pronouncement: 28.11.2025 O R D E R Per Nikhil Choudhary, A.M.: This Is An Appeal Filed By The Department Against The Orders Of The Ld. Cit(A), Wherein The Ld. Cit(A) Has Deleted The Addition Of Rs.1,70,77,516/- That Was Made By The Ld. Assessing Officer On Account Of Surplus Above 15% Of Gross Receipts. The Grounds Of Appeal Are As Under: - “1. Ld. Commissioner Of Income Tax (A) Has Erred In Law & Facts By Deleting The Addition Made Of Rs. 1,70,77,516/- On Account Of Amount Surplus Above 15% Without Appreciating The Facts That The Assessee Instead Of Utilizing This Amount Or Crediting This Amount To Income & Expenditure Account, This Sum Was Directly Credited To Balance Sheet. 2. Appellant Craves Leave To Modify/Amend Or Add Any One Or More Grounds Of Appeal.” 2. The Facts Of The Case Are That The Society Is Registered Under Section 12A Of The Income Tax Act, 1961 Vide Order Dated 11.12.2006 Of The Ld. Cit, Varanasi. From A Perusal Of The Papers Submitted By The Assessee As Well As The Data Available Online, The Ld. Assessing Officer Found That There Was A Receipt Of A Grant

For Appellant: Sh. Akash Agrawal, C.AFor Respondent: Sh. Amit Kumar, DR

Section 11Section 11(1)Section 11(6)Section 12A

been utilized. Thus, since the grants had been received for the specific purpose of the institution, these amounts were in the nature of corpus donation. Furthermore, even otherwise, since the entire amount had been utilized by the assessee during the prescribed time limits, the amount could not be treated

Haryana Saraswati Heritage Development Board, Panchkula, Haryana vs. DCIT/ACIT(E)(Circle-2) Chandigarh, Chandigarh

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

ITA 962/CHANDI/2025[2017-18]Status: DisposedITAT Chandigarh28 Nov 2025AY 2017-18

Section 11Section 12ASection 142(1)Section 143(2)Section 164(3)Section 270A

Income Tax Act, 1961, the requirement that a charitable or religious trust/institution must apply at least 85% of its Receipts (including donations, except corpus donations) for charitable purposes is laid down in Section 11(1)(a) of the Act. The relevant para is reproduced as under: "Income derived from property ... form of corpus fund donation (grant in aid) is out of ambit of taxable income. The Assessee was in receipt of voluntary contribution as Corpus Donation Fund which does not form part of total income, So, there was no surplus of excess of income over expenses in the case

Br Nath Pai Shikshan Sanstha, Kudal vs. ITO, Exemption, Exemption Ward

In the result the appeal filed by the assessee in ITA

ITA 1785/PUN/2025[2020-21]Status: DisposedITAT Pune28 Nov 2025AY 2020-21

Bench: Shri R. K. Panda & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.1782, 1783 & 1785/Pun/2025 निर्धारण वर्ष / Assessment Years : 2020-21 To 2022-23 Br Nath Pai Shikshan Vs. Cpc, Bangalore. Sanstha, Plot No.4, Midc, Near Vayman Garden Compound, Sindhudurg- 416520. Appellant Respondent Pan: Aabtb1496N Assessee By : Shri P. P. Jayaraman Revenue By : Smt. N. C. Shilpa Date Of Hearing : 19.11.2025 Date Of Pronouncement : 28.11.2025 आदेश / Order Per Bench : These Appeals Filed By The Assessee Are Directed Against The Separate Orders Dated 05.06.2025 Passed By Ld. Addl./Jcit(A)-6, Kolkata ['Ld. Cit(A)'] For The Assessment Years 2020-21 To 2022-23 Respectively. 2. Since Identical Facts & Common Issues Are Involved In The Above Captioned Three Appeals Of The Assessee, Therefore, We Proceed To Dispose Of The Same By This Common Order. 3. First, We Shall Take Up The Appeal Of The Assessee In Ita No.1785/Pun/2025 For A.Y. 2020-21 As The Lead Case For Adjudication.

For Appellant: Shri P. P. JayaramanFor Respondent: Smt. N. C. Shilpa

Section 11Section 12ASection 143(1)

order dated 20.09.2022, adjustments were made on entire income of the assessee trust including the corpus donation, voluntary donation and other income on the ground that the assessee did not filed the requisite form 10B along with the return of income and the CPC assessed the total taxable income entirely

Br Nath Pai Shikshan Sanstha, Kudal vs. ITO, Exemption

In the result the appeal filed by the assessee in ITA

ITA 1783/PUN/2025[2021-22]Status: DisposedITAT Pune28 Nov 2025AY 2021-22

Bench: Shri R. K. Panda & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.1782, 1783 & 1785/Pun/2025 निर्धारण वर्ष / Assessment Years : 2020-21 To 2022-23 Br Nath Pai Shikshan | Vs. Cpc, Bangalore. Sanstha, Plot No.4, Midc, Near Vayman Garden Compound, Sindhudurg- 416520. Pan: Aabtb1496N Appellant Respondent Assessee By : Shri P. P. Jayaraman Revenue By : Smt. N. C. Shilpa Date Of Hearing : 19.11.2025 Date Of Pronouncement : 28.11.2025 आदेश / Order Per Bench : These Appeals Filed By The Assessee Are Directed Against The Separate Orders Dated 05.06.2025 Passed By Ld. Addl./Jcit(A)-6, Kolkata ['Ld. Cit(A)'] For The Assessment Years 2020-21 To 2022-23 Respectively. 2. Since Identical Facts & Common Issues Are Involved In The Above Captioned Three Appeals Of The Assessee, Therefore, We Proceed To Dispose Of The Same By This Common Order. 3. First, We Shall Take Up The Appeal Of The Assessee In Ita No.1785/Pun/2025 For A.Y. 2020-21 As The Lead Case For Adjudication.

For Appellant: Shri P. P. JayaramanFor Respondent: Smt. N. C. Shilpa

Section 11Section 12ASection 143(1)

Br Nath Pai Shikshan Sanstha, Kudal vs. ITO, Exemption, Exemption Ward

In the result the appeal filed by the assessee in ITA

ITA 1782/PUN/2025[2022-23]Status: DisposedITAT Pune28 Nov 2025AY 2022-23

Bench: Shri R. K. Panda & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.1782, 1783 & 1785/Pun/2025 निर्धारण वर्ष / Assessment Years : 2020-21 To 2022-23 Br Nath Pai Shikshan Vs. Cpc, Bangalore. Sanstha, Plot No.4, Midc, Near Vayman Garden Compound, Sindhudurg- 416520. Pan: Aabtb1496N Appellant Respondent Assessee By : Shri P. P. Jayaraman Revenue By : Smt. N. C. Shilpa Date Of Hearing : 19.11.2025 Date Of Pronouncement : 28.11.2025 आदेश / Order Per Bench : These Appeals Filed By The Assessee Are Directed Against The Separate Orders Dated 05.06.2025 Passed By Ld. Addl./Jcit(A)-6, Kolkata ['Ld. Cit(A)'] For The Assessment Years 2020-21 To 2022-23 Respectively. 2. Since Identical Facts & Common Issues Are Involved In The Above Captioned Three Appeals Of The Assessee, Therefore, We Proceed To Dispose Of The Same By This Common Order. 3. First, We Shall Take Up The Appeal Of The Assessee In Ita No.1785/Pun/2025 For A.Y. 2020-21 As The Lead Case For Adjudication.

For Appellant: Shri P. P. JayaramanFor Respondent: Smt. N. C. Shilpa

Section 11Section 12ASection 143(1)

Mig Cricket Club, Mumbai vs. DCIT(E)-2, Mumbai

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

ITA 5721/MUM/2025[2014-15]Status: DisposedITAT Mumbai28 Nov 2025AY 2014-15

Bench: Shri Amit Shukla & Shri Vikram Singh Yadavassessment Year : 2014-15 Mig Cricket Club, Dcit(E)-2, Mig Colony, Mtnl Building, Mig Cricket Club, Vs. Cumballa Hill, Ramkrishna Paramhans Marg, Mumbai-400026. Bandra East, Mumbai-400051. Pan : Aaatm4779J (Appellant) (Respondent) For Assessee : Shri Anil Sathe For Revenue : Shri Annavaran Kosuri, Sr.Dr Date Of Hearing : 27-11-2025 Date Of Pronouncement : 28-11-2025

For Appellant: Shri Anil SatheFor Respondent: Shri Annavaran Kosuri, Sr.DR

Section 11Section 143(1)

file of the Assessing Officer with a direction to recompute the income of the assessee after granting exemption under section II and treating the corpus donations as capital receipts, and allowing the 15% statutory deduction under section 11(1)(a) as claimed in accordance with the law.” 12. In light

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

Bench: Shri B.M. Biyani & Shri Paresh M. Joshi

Section 124ASection 144Section 69A

itnpase an undue burden on a Trust dedicated solely to religious and charitable objectives. 15. During FY 2016-1 7, the Appellant received corpus donations for temple construction totaling Rs. 42,75,350/- iti’cash and Rs. 31,31,131/- by cheque from the Patni Group. Due to demonetization ... 353/Ind/2025 - AY 2017-18 16. At the onset, the addition is illegal and arbitrary, as the Ld. AO failed to recognize that corpus donations are not taxable, even if the Trust is not registered under Section 12AA. Such donations acquire the character of capital receipts. Reliance is placed on Chandraprabhu

The Jain Kasar Samaj Sanstha, Sangli, Maharashtra vs. The CIT (Exemption), Pune, Maharashtra

In the result, the appeal filed by the Assessee is devoid of merits and the

ITA 2613/PUN/2024[2024-2025]Status: DisposedITAT Pune27 Nov 2025AY 2024-2025

For Appellant: N O N EFor Respondent: Shri Udaya Bhaskar Jakke

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

trust/institution. (ii) You have submitted ledger account of donation receipts. You have specifically requested to furnish year-wise list of all donations received (including corpus donations etc.) during the last 3 years / since inception, whichever is later viz. name of donor, address of donor, amount of donation, mode of donation