“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

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 2612/PUN/2024[2024-2025]Status: DisposedITAT Pune27 Nov 2025AY 2024-2025

For Appellant: ΝΟΝΕFor 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

St. Francis Xavier Church, Panvel vs. Income Tax Officer (Exemption), Thane

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

ITA 5883/MUM/2025[2024-25]Status: DisposedITAT Mumbai25 Nov 2025AY 2024-25

Bench: Justice (Retd.) Shri C.V. Bhadang & Shri Vikram Singh Yadavassessment Year : 2024-25 St. Francis Xavier Church Trust, Income Tax Officer, Plot 379/B, Behind Orion Mall Exemption Ward, Thane & S.T. Depot, Vs. Quershi Mansion, Panvel-410206. Gokhale Road, Pan : Aaets4913N Naupada, Thane-400602. (Appellant) (Respondent) For Assessee : None For Revenue : Smt. B. Brahma Vidya Date Of Hearing : 25-11-2025 Date Of Pronouncement : 25-11-2025 O R D E R Per Vikram Singh Yadav, A.M : This Is An Appeal Filed By The Assessee Against The Order Of The Learned Addl/Jcit(A)-Agra, Dated 29-07-2025, Pertaining To Assessment Year (Ay) 2024-25, Wherein The Assessee Has Taken The Following Grounds Of Appeal: “1.1. On The Facts & In Circumstances Of The Case & In Law The Learned Commissioner Of Income-Tax (Appeals) [Cit(A)] Erred In Confirming The Denial Of Exemption/Deductions Under Section 11 Of The Act Resorted To By The Centralized Processing Centre [Cpc), Income Tax Department, Bengaluru (The Learned Assessing Officer) While Processing The Return Of Income Under Section 143(1) Of The Act On The Grounds That The Audit Report In Form 10-Bb Was Filed Belatedly, Though With The Return Of Income Which Was Filed Within The Extended Time Limit Under Section 139(1) Of The Act.

For Appellant: NONEFor Respondent: Smt. B. Brahma Vidya

Section 11Section 11(1)(a)Section 11(2)Section 11(6)Section 12ASection 139(1)Section 143(1)Section 143(1)(a)

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

Jai Kankaria Foundation, Kolkata vs. ITO, Ward 1(1), Exempt, Kolkata

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

ITA 2146/KOL/2025[2019-2020]Status: DisposedITAT Kolkata24 Nov 2025AY 2019-2020

Bench: Shri George Mathan & Shri Rakesh Mishraआयकर अपील सं/Ita No.2146/Kol/2025 (निर्धारण वर्ा / Assessment Year : 2019-2020) Jai Kankaria Foundation Vs Cpc, Bangalore/ 5, Middleton Street, Kolkata Ito Ward-1(1), Exempt, Kolkata Pan No. :Aaatj 2147 F (अपीलधर्थी /Appellant) .. (प्रत्यर्थी / Respondent) निर्धाररती की ओर से /Assessee By Shri Soumitra Choudhury & Shri Pranobesh Sarkar, Advocates रधजस्व की ओर से /Revenue By : Shri Sandeep Kumar Mehta, Sr. Dr सुनवाई की तारीख / Date Of Hearing : 24/11/2025 घोषणा की तारीख/Date Of Pronouncement : 24/11/2025 आदेश / O R D E R Per George Mathan, Jm : This Is An Appeal Filed By The Revenue Against The Order Of The Ld. Addl/Cit(A)-7, Delhi, Dated 14.07.2025 For The Assessment Year 2019-2020 2. It Was Submitted By The Ld. Ar That The Appeal Of The Assessee Has Been Dismissed By The Ld.Cit(A) On Account Of Delay Of 28 Days. In This Regard, Ld. Ar Drew Our Attention To The Judgment Of The Hon’Ble Supreme Court In Miscellaneous Application No.21 Of 2022 In Suo Motu Writ Petition (C) No.3 Of 2020, Dated 10.01.2022, Wherein The Hon’Ble Supreme Court Has Directed To Exclude The Period Of Limitation For The Period As Mentioned In The Said Judgment On Account Of Covid-19. The Relevant Observations Of The Hon’Ble Supreme Court Are As Under :- 4. The Present Miscellaneous Application Has Been Filed By The Supreme Court Advocates-On-Record Association In The Context Of The Spread Of The New Variant Of The Covid-19 & The Drastic Surge In The Number Of Covid Cases Across The Country. Considering The Prevailing Conditions, The Applicants Are Seeking The Following:

For Respondent: Shri Sandeep Kumar Mehta, Sr. DR

Section 12ASection 138Section 143(1)

file of Assessing Officer for verification as to whether the claim of the assessee trust in respect of donation is general donation or corpus donation. 5. We have considered the rival submissions. A perusal of the order of the ld. CIT(A) shows that the appeal of the assessee ... Assessing Officer for verification as to whether the exemption claimed by the assessee trust in respect of donation is general donation or corpus donation. If it is corpus donation, then no addition shall be made. 6. In the result, appeal of the assessee is allowed for statistical purposes. Order dictated

Dudhsagar Research and Dement Association, Mehsana vs. The Dy.CIT, Circle-1, Exemption, Ahmedabad

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

ITA 203/AHD/2025[2017-18]Status: DisposedITAT Ahmedabad17 Nov 2025AY 2017-18

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

For Appellant: Shri S N Divatia, ARFor Respondent: Shri R P Rastogi, CIT-DR

Section 11Section 11(1)(d)Section 13(8)Section 2(15)Section 250

object of general public utility, the exemption u/s 11&12 were not admissible and sec. 13(8) was applicable as well as treating the corpus donation amounting to Rs. 7,45,56,979/- as revenue receipt so that sec.11(1)(d) was not applicable, is wholly illegal, unlawful and against ... erred in law and or on facts in computing the total taxable income by disallowing exemption u/s 11 & 12 as well as treating the corpus donation as revenue receipt. 3.2 That in the facts and circumstances of the case, the decision of ITAT Ahmedabad Bench

Dudhsagar Research and Dement Association, Mehsana vs. The Dy.CIT, Cicle-1, Exemption, Ahmedabad

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

ITA 202/AHD/2025[2016-17]Status: DisposedITAT Ahmedabad17 Nov 2025AY 2016-17

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

For Appellant: Shri S N Divatia, ARFor Respondent: Shri R P Rastogi, CIT-DR

Section 11Section 11(1)(d)Section 13(8)Section 2(15)Section 250

Deputy Commissioner of Income Tax, Chennai vs. Jaya Educational Trust, Thiruvallur

ITA 237/CHNY/2025[2020-21]Status: DisposedITAT Chennai17 Nov 2025AY 2020-21

Bench: Shri Manu Kumar Giri & Shri S.R.Raghunathaआयकर अपील सं./ Ita. Nos.:234, 235, 236 & 237/Chny/2025 & Co Nos.59, 60, 61 & 62/Chny/2025 (In Ita Nos. 234, 235, 236 & 237/Chny/2025) िनधा"रण वष" / Assessment Years: 2016-17, 2017-18, 2018-19 & 2020-21 Deputy Commissioner Of Jaya Educational Trust, Income Tax, Vs. No.8, Krishnapuram, Ii Main Road, Central Circle -1(2), Thiruninravur, Chennai. Thiruvallur – 602 024. [Pan:Aaatj-0369-D] (अपीलाथ#/Appellant) ($%थ#/Respondent) Assessee By : Shri. Y. Sridhar, F.C.A. Department By : Shri. Bipin C.N., C.I.T. सुनवाई की तारीख/Date Of Hearing : 26.08.2025 घोषणा की तारीख/Date Of Pronouncement : 17.11.2025 आदेश /O R D E R Per Bench :

For Appellant: Shri. Y. Sridhar, F.C.AFor Respondent: Shri. Bipin C.N., C.I.T

Section 11Section 13Section 13(1)(c)Section 250Section 40A(3)

Commissioner of I.T. (Appeals) is opposed to law and facts of the case. 2. The ld. CIT(A) erred in allowing the corpus donation of Rs.14,51,14,000/- disallowed by the AO and which was not considered for exemption u/s.11 of the Act and further taxing the surplus income

Deputy Commissioner of Income Tax, Chennai vs. Jaya Educational Trust, Thiruvallur

ITA 236/CHNY/2025[2018-19]Status: DisposedITAT Chennai17 Nov 2025AY 2018-19

For Appellant: Shri. Y. Sridhar, F.C.AFor Respondent: Shri. Bipin C.N., C.I.T

Section 11Section 13Section 13(1)(c)Section 250Section 40A(3)

Deputy Commissioner of Income Tax, Chennai vs. Jaya Educational Trust, Thiruvallur

ITA 235/CHNY/2025[2017-18]Status: DisposedITAT Chennai17 Nov 2025AY 2017-18

For Appellant: Shri. Y. Sridhar, F.C.AFor Respondent: Shri. Bipin C.N., C.I.T

Section 11Section 13Section 13(1)(c)Section 250Section 40A(3)

Deputy Commissioner of Income Tax, Chennai vs. Jaya Educational Trust, Thiruvallur

ITA 234/CHNY/2025[2016-17]Status: DisposedITAT Chennai17 Nov 2025AY 2016-17

For Appellant: Shri. Y. Sridhar, F.C.AFor Respondent: Shri. Bipin C.N., C.I.T

Section 11Section 13Section 13(1)(c)Section 250Section 40A(3)

Kjsl Foundation, Delhi vs. Income Tax Officer, Delhi

In the result, the Assessee’s appeal is allowed for statistical purposes

ITA 5633/DEL/2025[2023-24]Status: DisposedITAT Delhi12 Nov 2025AY 2023-24

Bench: Shri Mahavir Singh, Hon’Bleasstt. Year : 2023-24

For Appellant: Ms. Shakshi Panday, AdvFor Respondent: Shri Manoj Kumar, Sr. DR

Section 11(1)Section 11(1)(d)Section 115BSection 143(1)

evidence despite adequate opportunity. Hence, Ld. Addl/JCIT(A) in the absence of any rebuttal or supporting documentation, the claim that the donations were corpus donations cannot be accepted. Therefore, in the absence of any response or supporting evidence from the assessee, the addition of Rs. 10 lacs made under section ... that AO erred in law and on facts by invoking the provisions of Section 115BBI of the Act and taxing the corpus donations received by the appellant at the maximum marginal rate, disregarding that such donations are exempt under section 11(1)9d) of the Act when received with specific

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

confirming the additions made by the Assessing Officer, wherein an addition of ₹32,74,493/- was made on account of alleged voluntary and corpus donations as anonymous as appellant failed to prove record of Menaba Charitable Trust vs. ITO Asst. Year : 2017-18 identity of donors liable to tax u/s115BBC

Shree Jagat Guru Brahmanand Gaushala Samiti, Panipat vs. CIT(E), Chandigarh

ITA 297/DEL/2022[-]Status: DisposedITAT Delhi03 Nov 2025

Bench: SHRI SATBEER SINGH GODARA (Judicial Member), SHRI NAVEEN CHANDRA (Accountant Member)

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

shall form part of the corpus) are the income of a charitable, religious or charitable cum religious trust. Therefore, in the present case, the corpus donation shown by the applicant on record during FY 2015- 16, 2017-18 & 2018-19 (and for any other previous years) is the income ... activities to be carried out in light thereof, the CIT(Exemption) herein has only gone by some alleged application involving the corpus donations and govt. grants in various assessment years (supra). That being the case, we are of the considered view that such an issue of corpus grants etc. could

Sri Sathya Sai Loka Seva Welfare Trust, Bangalore vs. Commissioner of Income Tax, Exemptions, Bangalore

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

ITA 1378/BANG/2025[2024-25]Status: DisposedITAT Bangalore31 Oct 2025AY 2024-25

Bench: Shri.Laxmi Prasad Sahu & Shri.Keshav Dubeyassessment Year : 2024-25 M/S. Sri Sathya Sai Loka Seva Welfare Trust, Vs. Cit(E), 313-D 9Th A Main 5Th Block, Jayanagar, Bangalore. Bangalore – 560 041, Karnataka. Pan : Aawts 7686 Q Appellant Respondent Assessee By : Shri. Raghunandan, Ca Revenue By : Shri. Muthu Shankar, Cit(Dr)(Itat), Bangalore. Date Of Hearing : 28.10.2025 Date Of Pronouncement : 31.10.2025

For Appellant: Shri. Raghunandan, CAFor Respondent: Shri. Muthu Shankar, CIT(DR)(ITAT), Bangalore

learned CIT(E) and there is total revenue donation of Rs.7,80,000/-. The details given in Paper Book Page No.17 where the corpus donation is only Rs.3 lakhs and revenue donation is Rs.7,80,000/-. Page 2 of 2 2. On the other hand, learned DR relied

Agrasen Medical Relief & Research Society, Jaipur vs. ITO(E), Ward-1, Jaipur

In the result, the appeal of the assessee is allowed

ITA 1026/JPR/2025[2016-17]Status: DisposedITAT Jaipur30 Oct 2025AY 2016-17

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI, AM आयकरअपीलसं./ITA No. 1026/JPR/2025 निर्धरणवर्ष / AssessmentYear : 2016-17 Agrasen Medical Relief & Research Society Central Spine, Sector -7, Vidhyadhr Nagar Jaipur - 302 039 (Raj) बनाम Vs. अपीलार्थी / Appellant स्थायीलेखा सं. / जीआईआरसं./PAN/GIR No.: AAATA 7540F The ITO (E) Ward - 1 Jaipur प्रत्यर्थी / Respondent निर्धारिती की ओरसे / Assesseeby :Shri P.C.Parwal, CA राजस्व की ओरसे /Revenue by: Shri Gautam Singh Choudh

For Appellant: Shri P.C.Parwal, CAFor Respondent: Shri Gautam Singh Choudhary, JCIT-DR

Section 11Section 12ASection 12A(1)(ac)Section 143(3)Section 194JSection 2(15)Section 80G

appeal of assessee. 2. The Ld. Addl. CIT(A) has erred on facts & in law in upholding the action of AO in treating the corpus donation received by the assessee as voluntary donation and thereby confirming the addition of Rs.30,19,100/-. It has further erred in not accepting ... alternate contention of assessee that even if corpus donation is considered as voluntary donation, then also no addition can be made as assessee is eligible for exemption u/s 11 of the Act by holding that since the assessee is not registered u/s 12A of the Act, it is not eligible

Neuro Update Chennai, Chennai vs. ITO, Exemption Ward-1, Chennai

In the result, the appeal of the assessee is allowed

ITA 1480/CHNY/2025[2016-17]Status: DisposedITAT Chennai30 Oct 2025AY 2016-17

Bench: Shri Aby T Varkey & Shri S.R.Raghunatha

For Appellant: Shri. G. Sitharaman, CA &For Respondent: Shri. R. Raghupathy, Addl. C.I.T

Section 11Section 12ASection 2(15)Section 250

facts in upholding the additions made by the Assessing Officer ("AO") amounting to ₹61,15,273/-, being (a) excess of income over expenditure; (b) corpus donation received; and (c) donations made to other charitable :-2-: ITA. No:1480 /Chny/2025 trusts, by treating them as taxable under the head "Income from ... under: Excess of income over expenditure as per income and 5,15,215 expenditure statement Add Donation to other Trusts 55.00,058 Add: Corpus Donations Received 1,00,000 Taxable Income 61,15,273 6. Aggrieved by the order of the Assessing Officer the assessee preferred an appeal before

Versova Kokni Sunni Jamat Trust, Mumbai vs. ITO, (E) (2)(4), Mumbai

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

ITA 6872/MUM/2024[2014-15]Status: DisposedITAT Mumbai24 Oct 2025AY 2014-15

Bench: Shri Saktijit Dey, Hon’Ble & Shri Narendra Kumar Billaiya, Hon’Ble

For Appellant: Revenue byFor Respondent: Ms. Kavitha Kaushik, Sr. D/R

Section 11Section 12A

Kolkata [hereinafter ‘the ld. CIT(A)’] dated 30/10/2024, pertaining to AY 2014-15. 2. The grievance of the assessee reads as under :- “Corpus Donations 1. On facts and circumstances of the case and in law CIT(A) passed Order based on surmise, conjecture, suspicion and doubt. Any order passed only ... based on presumption and guess work. 3. On facts and circumstances of the case and in law the ld. CIT(A) erred in disallowing Corpus Donation of Rs. 8,99,811/-terming the documents submitted as FAKE. Capital Receipts are not taxed irrespective of fact whether the trust is registered

Children Toy Foundation, Mumbai vs. CIT (Exemption), Mumbai

In the result, the appeal of the assessee bearing ITA 1345/Mum/2022 is dismissed

ITA 1345/MUM/2022[2017-18]Status: DisposedITAT Mumbai17 Oct 2025AY 2017-18

Bench: Shri Om Prakash Kant & Shri Anikesh Banerjee

For Appellant: NoneFor Respondent: Shri R.A. Dhyani (CIT-DR)

Section 11Section 12ASection 143(3)Section 263

treated the assessment order as erroneous and prejudicial to the interest of the revenue on the ground that the Ld.AO had not disallowed the corpus donation amount to Rs.9,46,608/- and addition to earmarked fund amount to Rs.2,08,456/- which was also not added back to the total ... account of non-filing of the audit report in Form No. 10B as required under the Act. It is further noted that the corpus donations, earmarked funds, and accumulations were rightly identified by the Ld. CIT in the revisional order, wherein it was observed that the Ld. AO had erroneously

Acharya Shree Vidhyasagar Dayoday Pashu Sewa Kendra Tendukheda Damoh, Tendukheda Damoh vs. Commissioner of Income Tax(Exemption), Bhopal

In the result, both the appeals in ITA Nos

ITA 32/JAB/2024[NA]Status: DisposedITAT Jabalpur30 Sept 2025

Bench: SH. KUL BHARAT, VICE PRESIDENT AND SH. NIKHIL CHOUDHARY (Accountant Member)

For Appellant: Sh. Sameer Jain, Sh. Nishant Jain & Dr. H.SFor Respondent: Sh. Shravan Kumar Meena, CIT DR

Section 10Section 12ASection 12A(1)(ac)Section 80GSection 80G(5)

details of donations were furnished. Subsequently, another notice was issued on 2.02.2024 to submit the complete details with regard to both corpus and non-corpus donation. In response to this, the assessee filed an adjournment letter. Yet another notice was issued on 14.02.2024 to submit the complete details. In response

Achariya Shree Vidhya Sagar Dayoday Pashu Seva Kendra Tendukheda Damoh, Vidhya Nagar Tendukheda Damoh vs. Commissioner (Exemption), Bhopal

In the result, both the appeals in ITA Nos

ITA 31/JAB/2024[NA]Status: DisposedITAT Jabalpur30 Sept 2025

Bench: SH. KUL BHARAT, VICE PRESIDENT AND SH. NIKHIL CHOUDHARY (Accountant Member)

For Appellant: Sh. Sameer Jain, Sh. Nishant Jain & Dr. H.SFor Respondent: Sh. Shravan Kumar Meena, CIT DR

Section 10Section 12ASection 12A(1)(ac)Section 80GSection 80G(5)

Tirupur Vision Rotary Trust, Tirupur vs. ACIT, Exemptions, Coimbatore

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

ITA 1102/CHNY/2025[2022-23]Status: DisposedITAT Chennai29 Sept 2025AY 2022-23

Bench: Shri Manu Kumar Giri & Shri Jagadish

For Appellant: Shri S. Sridhar, Advocate(Erode)For Respondent: Shri R. Anitha, Addl. CIT

Section 11Section 11(5)Section 119(2)(b)Section 143(1)

claiming exemption of Rs.12,84,457/-. In the intimation issued u/s. 143(1) of the Act, the CPC disallowed the assessee’s claim of corpus donations of Rs. 29,57,595/-, and did not allow exemption u/s. 11 & 12 of the Act , on the ground that the assessee ... have heard the rival submissions and perused the material available on record. The CPC has disallowed the assessee’s claim of exemption towards corpus donations without providing adequate opportunity to the assessee and as regards to denial of exemption under sections 11 & 12 of the Act for the reason that