“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, Exemptions Ward, Trichy vs. Arulmigu Swaminatha Swami Thirukkovil, Kumbakonam

In the result, the appeals filed by the revenue in ITA Nos

ITA 370/CHNY/2025[2013]Status: DisposedITAT Chennai30 Jul 2025

Bench: Shri S.S.Viswanethra Ravi & Shri S.R.Raghunathaआयकर अपील सं./Ita Nos.: 370 & 368/Chny/2025 & Co Nos.32 & 33/Chny/2025 (In Ita Nos.: 370 & 368/Chny/2025) धनिाारण वर्ा / Assessment Year: 2013-14 & 2014-15 Income Tax Officer, Arulmigu Swaminatha Swami Exemptions Ward, Trichy, Thirukkovil, Vs. The Executive Officer, Swamimalai, Kumbakonam – 612 301. [Pan: Aaata-6446-J] (अपीलाथी/Appellant) (Respondent/Cross Objector) अपीलाथीकीओरसे/ Appellant By : Shri. P. Krishna Kumar, J.C.I.T. प्रत्यथीकीओरसे/Respondent By : Shri. N. Arjun Raj, Advocate सुनवाई की तारीख/Date Of Hearing : 09.05.2025 घोर्णा की तारीख/Date Of Pronouncement : 30.07.2025 आदेश /O R D E R Per Bench: These Appeals Filed By The Revenue & Cross Objections Filed By The Assessee Are Directed Against The Order Of The Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi, For The Assessment Years 2013-14 & 2014-15, Vide Order Dated 20.12.2024. Since The Facts Are Identical & Issues Are Common, Appeals Filed By The Revenue & Cross Objections Filed By The Assessee Were Heard & Are Being Disposed Of By This Consolidated Order.

For Appellant: Shri. P. Krishna Kumar, J.C.I.TFor Respondent: Shri. N. Arjun Raj, Advocate

Section 10Section 11Section 12A(1)(b)Section 139Section 139(1)Section 147

voluntary contribution does not generally have the character of income but deemed income in case of non-corpus donations to enforce the requirement of the application of prescribed part of income for approved objects. ITA Nos.: 370 & 368/Chny/2025 & :-11-: CO Nos.32 & 33/Chny/2025 32. The Assessee being a government-controlled entity

The Income Tax Officer, Exemptions Ward, Trichy vs. Arulmigu Swaminatha Swami Thirukkovil, Kumbakonam

In the result, the appeals filed by the revenue in ITA Nos

ITA 368/CHNY/2025[2014-15]Status: DisposedITAT Chennai30 Jul 2025AY 2014-15

For Appellant: Shri. P. Krishna Kumar, J.C.I.TFor Respondent: Shri. N. Arjun Raj, Advocate

Section 10Section 11Section 12A(1)(b)Section 139Section 139(1)Section 147

Akhil Sagar Vanshiyjiremali Samaj Dharmadaynyas Pandharpur, Pandharpur vs. CIT Exemption, Pune

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

ITA 578/PUN/2025[-]Status: DisposedITAT Pune29 Jul 2025

Bench: Shri R.K. Panda & Ms. Astha Chandra

For Appellant: Shri R.P. DawareFor Respondent: Shri Ramnath P. Murkunde

Section 12Section 12ASection 12A(1)(ac)Section 139

have not submitted details of donation in the requisite format. You were 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. full name, complete Postal address & PAN of donor, date & mode of donation

Akhil Bharatiyha Maheshwari Educational & Charitable Trust, Pune vs. CIT Exemption, Pune

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

ITA 2790/PUN/2024[- NA -]Status: DisposedITAT Pune28 Jul 2025

Bench: Shri R.K. Panda & Ms. Astha Chandra

For Appellant: Shri Nikhil MuthaFor Respondent: Shri Amol Khairnar

Section 12ASection 12A(1)(ac)

charitable activities actually carried out by your trust. (iv) You were 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 / receipts

Bastuhara Sahayata Samiti, Kolkata vs. ITO, Ward 1(2)(Exemption), Kolkata

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

ITA 444/KOL/2025[2016-17]Status: DisposedITAT Kolkata28 Jul 2025AY 2016-17

Bench: Shri Duvvuru Rl Reddy, Vice-(Kz) I.T.A. No. 444/Kol/2025 Assessment Year: 2016-2017 Bastuhara Sahayata Samiti,……………….…Appellant 27/1B, Bidhan Sarani, Srimini Market, Kolkata-700006, West Bengal [Pan:Aaatb7422R] -Vs.- Income Tax Officer,……………………………..Respondent Ward-1(2), (Exemption), Kolkata, Office Of The Income Tax Officer, 10B, Middleton Row, Kolkata-700071 Appearances By: Shri S.K. Tulsian, Advocate & Ms. Puja Somani, C.A., Appeared On Behalf Of The Assessee Shri Somnath Das Biswas, Sr. D.R., Appeared On Behalf Of The Revenue Date Of Concluding The Hearing: May 20, 2025 Date Of Pronouncing The Order: July 28, 2025 O R D E R

Section 119(2)(b)Section 12ASection 142(1)Section 143(2)Section 143(3)

nature that has been capitalized. The assesese could not submit any proof to substantiate the claim. A number of certificates submitted towards proof of Corpus Donation showed that the certificates were printed by the assessee himself and then signature of the donors were obtained. The assesee could not furnish ... raised in this appeal before the Hon’ble Tribunal. 9. Ground Nos. 4 to 6 of this appeal are against disallowance of deduction of corpus donation u/s 11(1)(d) of the Act and set apart claim u/s 11(2) of the Act which are as below: (4) That

Sri Gmh Harity Foundation, Davanagere vs. The Income Tax Officer- Exemption (Exemption Ward-1), Hubballi

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

ITA 442/BANG/2025[2025-26]Status: DisposedITAT Bangalore28 Jul 2025AY 2025-26

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Sri Ramanagowda S Gowdar, A.RFor Respondent: Sri E. Shridhar, D.R

Section 12ASection 80G

which no proof had been produced. The ld. CIT(E) further observed that the assessee received an amount of Rs.1,46,00,001/- as corpus donation towards the establishment of Oxygen Plant. The A.R. was asked to furnish the details of corpus donations which were received during the year

Sri Gmh Harity Foundation, Davanagere vs. The Income Tax Officer, Exemption, Exemption Ward-1, Hubballi

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

ITA 441/BANG/2025[2025-26]Status: DisposedITAT Bangalore28 Jul 2025AY 2025-26

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Sri Ramanagowda S Gowdar, A.RFor Respondent: Sri E. Shridhar, D.R

Section 12ASection 80G

My Ecosocial Planet Foundation, Pune vs. CIT Exemption, Pune

In the result, both the appeals in ITA Nos

ITA 2794/PUN/2024[- NA -]Status: DisposedITAT Pune25 Jul 2025

Bench: Shri R.K. Panda & Ms. Astha Chandraआयकर अपील सं. / Ita Nos. 2793 & 2794/Pun/2024 My Ecosocial Planet Foundation, Cit (Exemptions), Pune H-264, Sant Kripa N.I.A.S.O. Baner, Pune-411045 Vs. Pan : Aancm4076G अपीलार्थी / Appellant प्रत्यर्थी / Respondent Assessee By : Shri Sharad A Vaze Department By : Shri Amol Khairnar Date Of Hearing : 17-07-2025 Date Of 25-07-2025 Pronouncement : आदेश / Order Per Astha Chandra, Jm : The Above Two Appeals Filed By The Assessee Are Directed Against The Separate Orders Both Dated 17.10.2024 Of The Ld. Commissioner Of Income Tax (Exemption), Pune (“Cit(E)”) Rejecting The Application(S) For Grant Of Registration U/S 12A & Approval U/S 80G Of The Income Tax Act, 1961 (The “Act”). For The Sake Of Convenience, Both These Appeals Were Heard Together & Are Being Disposed Of By This Common Order.

For Appellant: Shri Sharad A VazeFor Respondent: Shri Amol Khairnar

Section 10Section 11Section 12Section 12ASection 12A(1)(ac)Section 80G

applicable to your case. Please clarify with supporting documents. (iii) You were 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

My Ecosocial Planet Foundation, Pune vs. CIT Exemption, Pune

In the result, both the appeals in ITA Nos

ITA 2793/PUN/2024[- NA -]Status: DisposedITAT Pune25 Jul 2025

For Appellant: Shri Sharad A VazeFor Respondent: Shri Amol Khairnar

Section 10Section 11Section 12Section 12ASection 12A(1)(ac)Section 80G

Kowshika Sankethi Sangha, Bangalore vs. Income Tax Officer, Ward-1, Exemptions, Bangalore

Accordingly the appeal filed by the assessee is allowed for statistical purposes

ITA 880/BANG/2025[2018-19]Status: DisposedITAT Bangalore25 Jul 2025AY 2018-19

Bench: Shri Prashant Maharishi & Shri Soundararajan K.Assessment Year : 2018-19

For Appellant: S/Shri C R Krishna & Sachin Mehta, CAsFor Respondent: Shri Shivanand H Kalakeri, CIT(DR)(ITAT), Bengaluru

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

involved in this appeal is that income of the assessee trust is determined at Rs 80,26,057/- by not allowing the claim of corpus donation u/s 11 (1) (d) of the Act of Rs. 72,14,721/- and not allowing accumulation to the extent of 15 % of the gross ... which was denied by the CPC. Intimation u/s. 143(1) was passed on 31.1.2020. 4. The amount of Rs.80,26,057 is comprising of corpus donation u/s. 11(1)(d) of Rs.72,14,721 and further a sum of Rs.8,11,336 is amount accumulated

Bhagwan Vardhman Shwetamber Murtipujak Tapagacch Jain Sangh, Mumbai vs. Commissioner Income Tax, (Exemptions), Mumbai

In the result, appeal of the assessee is allowed

ITA 2378/MUM/2024[2012-13]Status: DisposedITAT Mumbai23 Jul 2025AY 2012-13

Bench: Shri Narendra Kumar Billaiya, Hon’Ble & Shri Anikesh Banerjee, Hon’Ble

For Appellant: Shri Dharan Gandhi, A/RFor Respondent: Shri Satyaprakash R. Singh, CIT, D/R

Section 11Section 11(1)(d)Section 12ASection 144Section 147Section 263

best of his judgment u/s 144 of the Act. 3. While scrutinising the return of income, the AO noticed that the assessee has received corpus donation of Rs. 38,42,558/- against which corpus expenditure of Rs. 10,97,699/- has been claimed to have been incurred. Since the assessee ... registered u/s 12A of the Act, the receipts were treated as revenue receipts in the absence of any documentary evidence the balance corpus donation to the tune of Rs. 27,44,859/- was treated as income of the assessee and the returned income of the assessee was assessed at Rs.36

Nnf State Chapter Telangana, Hyderabad vs. Income Tax Officer (Exemption), Ward 1(2), Hyderabad

In the result, the appeal is allowed for statistical purposes

ITA 152/HYD/2025[2020-21]Status: DisposedITAT Hyderabad18 Jul 2025AY 2020-21

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

Loknayak Jaiprakash Narayan Leprosy Eradication Trust, Mumbai vs. Income Tax Officer Exem Ward 1(4), Mumbai

In the result, grounds of appeal raised by assessee is allowed

ITA 2827/MUM/2025[2011-12]Status: DisposedITAT Mumbai18 Jul 2025AY 2011-12

Bench: Shri Pawan Singh(Physical Hearing) Loknayakjaiprakash Narayan Leprosy Ito Exemption Ward-1(4), Room No. 216, 2Nd Floor, Eradication Trust Vs Plot No. 16, Krishna Kunj, J.P. Nagar Mtnl Building, Peddar Road, Road No. 3, Goregaon East, Cumball Hill, Mumbai-400063. Mumbai-400026. [Pan No. Aaatl0220B] Appellant / Assessee Respondent / Revenue

Section 11(1)(d)Section 12ASection 147Section 148Section 250Section 254(1)

assessing officer recorded that assessee has not furnished any direction letter form the donor that they have given such donation as a corpus donation. The assessing officer treated such corpus donation as general donation and added to the total income of the assessee. Aggrieved by the action of assessing officer ... with regard to the donation of Rs. 10,21,500/- is now available and were furnished. The assessee prayed for considering such donation for corpus donation. The assessee also relied on the decision of Allahabad High Court in Dwarkadeesh Charitable Trust Vs ITO 98 ITR 557. In response to show

M/S. Gedee Medical Foundation, Coimbatore vs. CIT, Exemption, Chennai

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

ITA 521/CHNY/2025[-]Status: DisposedITAT Chennai15 Jul 2025

Bench: Shri George George K & Shri S.R. Raghunathaआयकर अपील सं./Ita No.:521/Chny/2025 M/S. Gedee Medical Foundation, The Commissioner Of Income Tax 1, Chettipalayam Road, Vs. (Exemption), Podanur, Chennai – 600 034. Coimbatore – 641 023. [Pan: Aabtg-5427-A] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से/Appellant By : Shri. R. Vijayaraghavan, Advocate ""थ" की ओर से/Respondent By : Ms. E. Pavuna Sundari, C.I.T.

For Appellant: Shri. R. Vijayaraghavan, AdvocateFor Respondent: Ms. E. Pavuna Sundari, C.I.T

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

legally untenable, especially when the objects, financial deployment, and mode of operations all substantiate a bona fide charitable intention. 12. The CSR contributions and corpus donations received from group companies were used for acquiring medical equipment and other capital assets for the hospital. These are aligned with the objects

Muslim Foundation for Renaissance Kolhapur, Kolhapur vs. Jurisdictional AO, Exemption Ward, Kolhapur

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

ITA 1046/PUN/2025[2021-22]Status: DisposedITAT Pune14 Jul 2025AY 2021-22

Bench: Dr.Manish Borad

For Appellant: Ms. Chaitee LondheFor Respondent: Shri Deepak Kumar Kedia

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

Without prejudice to the above ground, the learned Addl./Jt. Commissioner of Income Tax (Appeals) erred in facts and in law, in treating the corpus donations as income of the Appellant, without 2 Muslim Foundation for Renaissance Kolhapur appreciating that the corpus donations constitute a capital receipt and should ... ./Jt. Commissioner of Income Tax (Appeals) erred in not adjudicating or considering the ground preferred by the Appellant with respect to the amount of corpus donations being incorrectly reported. 4. Without prejudice to the above grounds, the learned Addl./Jt. Commissioner of Income Tax (Appeals) erred in facts

Shree Khandelwal Digambar Jain Foundation, Aurangabad vs. The Commissioner of Income Tax(Exemption), Pune

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

ITA 2555/PUN/2024[2024-25]Status: DisposedITAT Pune14 Jul 2025AY 2024-25

Bench: Dr.Manish Borad & Shri Vinay Bhamore

For Appellant: Shri Nikhil S PathakFor Respondent: Shri Amol Khairnar CIT-DR

Section 12ASection 2(15)Section 8Section 80G

charitable objects of the organisation. It is also noticed from the balance sheet that the major part of the income has been shown as corpus donations and has been invested in FDRs / bank accounts without its utilization on objectives and are lying idle. Therefore, it appears that the applicant ... charitable activities as yet and, therefore, the present application is premature. 8. Further, the applicant has received donations which have been categorized as 'corpus' donations. However, the applicant, in all receipts has, by itself written the donation to be corpus. As per Section 11(1)(d) of the Income

Shree Khandelwal Digambar Jain Foundation, Aurangabad vs. The Commissioner of Income Tax (Exemption), Pune

ITA 2554/PUN/2024[2024-25]Status: DisposedITAT Pune14 Jul 2025AY 2024-25

Bench: Dr. Manish Borad & Shri Vinay Bhamore

For Appellant: Shri Nikhil S PathakFor Respondent: Shri Amol Khairnar CIT-DR

Section 12ASection 2(15)Section 8Section 80G

charitable objects of the organization. It is also noticed from the balance sheet that the major part of the income has been shown as corpus donations and has been invested in FDRs. It appears that the applicant has not undertaken any charitable activities as yet and, therefore, the present application ... premature. 8. Further, the applicant has not received donations, which have been categorized as corpus donations. However, the applicant in all receipts has, by itself written the donation to be corpus. As per Section 11(1)(d) of the Income Tax Act, 1961, for donations to be treated as corpus

Badalpur Charity Trust, Mumbai vs. Income Tax Officer (Exemption)-1(1), Mumbai

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

ITA 2509/MUM/2025[2010-11]Status: DisposedITAT Mumbai09 Jul 2025AY 2010-11

Bench: Shri Narender Kumar Choudhry & Shri Omkareshwar Chidaraassessment Year: 2010-11

For Appellant: NoneFor Respondent: Shri Leyaqat Ali Aafaqui, Ld. Sr. A.R

Section 143(3)Section 250

vide order dated 26.12.2017 u/s 143(3) r.w.s. 147 of the Act, has made the addition of Rs.1,10,00,000/- on account of corpus donation received. 4. The Assessee, being aggrieved, though challenged the said addition before the Ld. Commissioner, however, in spite of affording multiple opportunities, made

Odia Samaj, Aradhna Enclave vs. Income-Tax Officer (Circle Exemp 2(1), Delhi), New Delhi

ITA 5251/DEL/2024[2018-19]Status: DisposedITAT Delhi09 Jul 2025AY 2018-19

Bench: Ms. Madhumita Roy & Shri Manish Agarwalassessment Year: 2018-19

Section 11Section 12ASection 142(1)Section 143(2)Section 143(3)Section 144BSection 80G(5)(vi)

restricted the addition to the tune of Rs. 2,00,00,000/- on account of donation not being corpus donation as claimed by the assessee trust and in view of that particular observation made by the Ld. CIT(A) the additional ground has been raised by the assessee ... certificate for registration under Section 12AA of the Act. The activities of the trust and the list of donors who had made corpus donation and the list of persons who had voluntarily contributed were also provided to the Ld. AO along with the income and expenditure statement, balance- sheet, bank

Bhagwandas Zalani Family Charitable Trust, Indore vs. CIT(E), Bhopal

ITA 777/IND/2024[-]Status: DisposedITAT Indore08 Jul 2025

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

Section 12ASection 80GSection 80G(5)

denial of registration is such that the assessee could not file 'direction letter' of the donors in support of 'corpus donations' received. When the CIT(E) show- caused assessee qua this point, the assessee filed a copy of sample receipt No. 46 (the same is scanned ... concluded that the donation received with specific instruction in writing from the donors to form as part of corpus, can only be termed as 'corpus donations'. Accordingly, the CIT(E) insisted on 'direction letter' of donors and in absence thereof, rejected assessee's submission. 7.2 Before