“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

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

ITA 776/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

Eeswara Seva Samithi, Davanagere vs. Income Tax Officer Exemption, (Exemptions Ward -1), Hubballi

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

ITA 396/BANG/2025[2025-26]Status: DisposedITAT Bangalore30 Jun 2025AY 2025-26

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year : 2025-26 Eeswara Seva Samithi 868/1, Balaji Tractors Pb Road Shankar Vihar Extension Ito (Exemptions Ward 1) Vs. Davanagere 577 006 Hubballi Karnataka Pan No : Aabte2673E Appellant Respondent

For Appellant: Sri Ramanagowda S Gowdar, A.RFor Respondent: Smt. Srinandini Das, D.R

Section 11Section 12A

land measuring 24 guntas near Jeeganahalli Village, at a cost of Rs.30,70,000/-. However, the assessee has not furnished details of donations / corpus donations received during the first year of inception. 3.3 The ld. CIT(E) further observed that during the F.Y 2023-24, the assessee received corpus donations ... assessee submitted that it has received major corpus donations of Rs. 4.60 Crore and Rs. 0.50 Crore from Mr. Sama Chaitanya Kumar, Hyderabad during the FYs 2023-24 and 2024-25 respectively. The assessee had purchased agricultural land and got approval for conversion of agricultural land to non-agricultural land

Shree Gurumalleshwara Hiriya Nagarikara Seva Samithi (R), Nanjanaguru vs. Income Tax Officer, Ward-1(1), Mysore

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

ITA 2292/BANG/2024[2016-17]Status: DisposedITAT Bangalore30 Jun 2025AY 2016-17

Bench: Shri Prashant Maharishi, Vice – & Shri Soundararajan K.Assessment Year : 2016-17

For Appellant: Shri Vageesh Hegde, CAFor Respondent: Ms. Neha Sahay, JCIT-DR

Section 147Section 148

Order of CIT (Appeals) is Rs. 73,88,533/- Page 2 of 5 liable to be set aside as it wrongly treated the corpus donation of Rs. 73,88,503/- as non-corpus donations and added the same to the total income of the Appellant on the following grounds ... that the Appellant has not discharged the burden of proving the exemption to the corpus donation received by the Appellant in the form of deposits made in the bank even though the Appellant submitted all documents in this regard; (b) that the Appellant has not submitted the documents related

M/S. Patna Womens College Trust, Ranchi vs. ITO Ward-1(2), Ranchi

The appeal of the assessee is allowed

ITA 495/RAN/2024[2018-19]Status: DisposedITAT Ranchi24 Jun 2025AY 2018-19

Bench: Shri Sonjoy Sarma & Shri Ratnesh Nandan Sahay

Section 12Section 143(3)Section 250

same duly formed part of the income in the audited books of account of the assessee and it is never claimed to be a corpus donation. In this context, the ld. AR submitted a copy of the computation sheet of ‘consolidated income & expenditure account for the year ended ... solely on the ground that no specific direction of utilization of the contribution was found and as such, it does not form part of corpus donation, which is not correct. We notice from the documents submitted by the assessee which is clearly reflected that the voluntary contribution of Rs.48

Ashirwad Charitable Trust, Mumbai vs. Deputy Commissioner of Income Tax (Exemptions) Circle, Pune

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

ITA 190/PUN/2024[2015-16]Status: DisposedITAT Pune20 Jun 2025AY 2015-16

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

For Appellant: Shri Raja B. SinghFor Respondent: Shri Ramnath P. Murkunde

Section 11Section 11(1)(a)Section 11(1)(d)Section 11(2)Section 12ASection 143(3)Section 147Section 154Section 2(15)

assessment u/s 143(3) of the Act on 29.12.2017 determining the assessed income at Rs.1,16,19,900/- making addition on account of corpus donations u/s 11(1)(d) of the Act by observing that the activities of the assessee trust are not charitable as per the provisions of section

Dharmbhaskar Rashtrasant Shripachlegavkar Maharj Pratishtan, Pune vs. Exemption Ward 1(2), Pune

In the result, both the appeals of the assessee in ITA No

ITA 2799/PUN/2024[2012-13]Status: DisposedITAT Pune18 Jun 2025AY 2012-13

For Appellant: Shri Abhay Shastri & Jasraj SutarFor Respondent: Shri Akhilesh Srivastava

Section 11Section 11(1)(d)Section 12Section 12ASection 143(3)Section 147Section 2(24)

basis and not headwise or statutory basis wherein Expenditure would be charge on the income, while the net income along with donations other than corpus donations will form eligible base out of which the appellant is expected to apply 75% (now 85%). Therefore, in my opinion, the manner of computation

Dharmbhaskar Rashtrasant Shripachlegavkar Maharj Pratishtan, Pune vs. Exemption Ward 1(2), Pune

In the result, both the appeals of the assessee in ITA No

ITA 2736/PUN/2024[2011-12]Status: DisposedITAT Pune18 Jun 2025AY 2011-12

For Appellant: Shri Abhay Shastri & Jasraj SutarFor Respondent: Shri Akhilesh Srivastava

Section 11Section 11(1)(d)Section 12Section 12ASection 143(3)Section 147Section 2(24)

Ampi Foundation, Kolkata vs. ITO, Ward 1(4), Exempt, Kolkata

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

ITA 365/KOL/2025[2022-23]Status: DisposedITAT Kolkata16 Jun 2025AY 2022-23

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishraampi Foundation, Deputy Director Of Income Unimark Asian, 16Th Floor, Tax, Cpc, Bengaluru, 52/1, Shakespeare Sarani, (Jurisdictional Assessing Kolkata - 700017 Vs Officer, Ward 1(4), (Pan: Aadta8073A) Exempt, Kolkata, 10, Middleton Row, Kolkata - 700071 (Appellant) (Respondent)

For Appellant: Siddarth Agarwal, AdvocateFor Respondent: Kallol Mistry, JCIT, Sr. DR

Section 11Section 11(1)(d)Section 12A(1)(ac)Section 12A(1)(b)Section 139(1)Section 143(1)Section 143(1)(a)Section 250

erred in sustaining the view of the Deputy Director of Income Tax, CPC, Bengaluru in denying the assessee exemption of 9,00,000 being corpus donation received during the year to which the assessee is entitled in terms of Section 12A(1)(b) read with Section

Annai Trust, Krishnagiri vs. ITO, Exemptions Ward, Salem

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

ITA 780/CHNY/2025[2018-19]Status: DisposedITAT Chennai11 Jun 2025AY 2018-19

Bench: Shri Ss Viswanethra Ravi & Shri Amitabh Shuklaआयकर अपील सं./Ita No.780/Chny/2025 Assessment Years: 2018-19 Annai Trust, The Income Tax Officer, D.No.25/235, Jinna Street, Exemptions Ward, Kaveripattinam(Viil) (Po), Salem Krishnagiri, Tamil Nadu 635 112. [Pan: Aadta6748A] (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) अपीलार्थी की ओर से/ Assessee By : Shri Girish Kumar, Advocate प्रत्यर्थी की ओर से /Revenue By : Ms.Anitha, Addl.Cit सुनवाई की तारीख/Date Of Hearing : 03.06.2025 घोषणा की तारीख /Date Of Pronouncement : 11.06.2025 आदेश / O R D E R Per Amitabh Shukla, A.M :

For Appellant: Shri Girish Kumar, AdvocateFor Respondent: Ms.Anitha, Addl.CIT

Section 10Section 11Section 143(1)(a)

this tribunal. 3.0 Per contra the Ld DR would like to rely upon the orders of lower authorities. It was submitted that items like corpus donations etc included in appellants claims were not admissible for any deductions. 4.0 We have heard rival submissions in the light of material on records

Mahansaria Enterprises Pvt Ltd, Mumbai vs. Pr. CIT, Mumbai-5, Mumbai

In the result, the appeal of the assessee is allowed

ITA 2158/MUM/2025[2020-21]Status: DisposedITAT Mumbai11 Jun 2025AY 2020-21

Bench: Shri Vikram Singh Yadav & Shri Rahul Chaudharyassessment Year : 2020-21 Mahansaria Enterprises Private The Principal Commissioner Of Limited, Income Tax (Pcit), 301-304, 3Rd Floor, Vs. Room No. 515, 5Th Floor, Peninsula Chambers, Aayakar Bhavan, Peninsula Corporate Park, Maharshi Karve Road, G.K. Marg, Lower Parel West, Mumbai-400020 Mumbai-400026 Pan : Aaacy1568L (Appellant) (Respondent) For Assessee : Shri Vipul Joshi, Adv. & Prashant Bhumare For Revenue : Shri Satyaprakash R. Singh, Cit-Dr Date Of Hearing : 14-05-2025 Date Of Pronouncement : 11-06-2025 O R D E R Per Vikram Singh Yadav, A.M : This Is An Appeal Filed By The Assessee Against The Order Of The Ld. Principal Commissioner Of Income Tax, Mumbai-5 [„Ld.Pcit‟] U/S. 263 Of The Income Tax Act, 1961 („The Act‟), Dated 17-03-2025, Pertaining To Assessment Year (Ay) 2020-21, Wherein The Assessee Has Taken The Following Grounds Of Appeal:

For Appellant: Shri Vipul Joshi, Adv. &For Respondent: Shri Satyaprakash R. Singh, CIT-DR

Section 143(3)Section 263Section 37(1)Section 80G

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

Health Foundation & Research Centre, Dahod vs. The ACIT, Circle-2, Exemption, Ahmedabad

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

ITA 483/AHD/2025[2017-18]Status: DisposedITAT Ahmedabad10 Jun 2025AY 2017-18

Bench: Ms. Suchitra Kamble & Shri Makarand V. Mahadeokar

For Appellant: Shri Sakar Sharma, ARFor Respondent: Shri Hargovind Singh, Sr.DR

Section 11Section 11(1)Section 11(1)(a)Section 11(2)Section 119(2)(b)Section 12ASection 12A(1)(b)Section 139(1)Section 143(2)Section 143(3)

accordingly, denied exemption under sections 11 and 12. The AO treated the entire income of the assessee as taxable, including corpus donations aggregating to Rs. 71,38,000/- and completed the assessment under section 143(3) of the Act, determining the total income ... were recorded on the merits of the additions made by the AO. The grounds relating to the exemption under section 11, the treatment of corpus donations, and claim of deduction under section 11(1)(a) were not adjudicated. 4. Aggrieved by the order of the CIT(A),NFAC, the assessee

St. Josephs Institute of Science and Technology Trust, Chennai vs. DCIT, Central Circle-1(3), Chennai

ITA 3297/CHNY/2024[2020-21]Status: DisposedITAT Chennai06 Jun 2025AY 2020-21

Bench: Shri Aby T. Varkey & Shri Jagadishआयकर अपील सं./Ita Nos.3293 & 3294/Chny/2024 निर्धारणवर्ष/Assessment Year: 2018-19 & 2020-21 St. Joseph'S Educational Trust, 56-C, Old Mahabalipuram Road, Sholinganallur, Chennai-600 119. [Pan: Aamts 3888 G] (अपीलार्थी/Appellant) V. The Dcit, Central Circle-1(3), Chennai. (प्रत्यर्थी/Respondent) आयकर अपील सं./Ita Nos.3295 To 3297/Chny/2024 निर्धारणवर्ष/Assessment Year: 2018-19 To 2020-21 St. Joseph'S Institute Of Science & Technology Trust, 56-C, Old Mahabalipuram Road, Sholinganallur, Chennai-600 119. [Pan: Aahts 9943 B] (अपीलार्थी/Appellant) V. The Dcit, Central Circle-1(3), Chennai. (प्रत्यर्थी/Respondent) अपीलार्थी की ओर से/ Appellant By : Mr. V. Balaji, Ca & Mr. K.R. Vasudevan, Advocate By Virtual प्रत्यर्थी की ओर से / Respondent By : Ms. Anitha, Addl.Cit सुनवाईकीतारीख/Date Of Hearing : 04.04.2025 घोषणाकीतारीख / Date Of Pronouncement : 06.06.2025 :: 2 ::

For Appellant: Mr. V. Balaji, CA &For Respondent: Ms. Anitha, Addl.CIT

Section 11Section 12ASection 139(1)Section 143(1)Section 270ASection 271A

declaring gross receipts of Rs.43,78,72,937/- and `Nil' taxable income and had shown in its books of accounts that it has received corpus donation of Rs.5,88,60,300/- by way of Demand Draft (DD) which RoI was processed u/s.143(1) of the Act and the same ... amount of shortfall in the application of funds to the extent of 85% of the income [including corpus donation which was treated as voluntary donations] received during the relevant previous year in accordance with section 11 of the Act. The AO is noted to have passed the assessment order u/s.153A

St. Joshephs Institute of Science and Technology Trust, Chennai vs. DCIT, Central Circle-193), Chennai

ITA 3296/CHNY/2024[2019-20]Status: DisposedITAT Chennai06 Jun 2025AY 2019-20

Bench: Shri Aby T. Varkey & Shri Jagadishआयकर अपील सं./Ita Nos.3293 & 3294/Chny/2024 निर्धारणवर्ष/Assessment Year: 2018-19 & 2020-21 St. Joseph'S Educational Trust, 56-C, Old Mahabalipuram Road, Sholinganallur, Chennai-600 119. (Pan: Aamts 3888 G) (अपीलार्थी/Appellant) V. The Dcit, Central Circle-1(3), Chennai. (प्रत्यर्थी/Respondent) आयकर अपील सं./Ita Nos.3295 To 3297/Chny/2024 निर्धारणवर्ष/Assessment Year: 2018-19 To 2020-21 St. Joseph'S Institute Of Science & Technology Trust, 56-C, Old Mahabalipuram Road, Sholinganallur, Chennai-600 119. [Pan: Aahts 9943 B] (अपीलार्थी/Appellant) V. The Dcit, Central Circle-1(3), Chennai. (प्रत्यर्थी/Respondent) अपीलार्थी की ओर से/ Appellant By : Mr. V. Balaji, Ca & Mr. K.R. Vasudevan, Advocate By Virtual प्रत्यर्थी की ओर से /Respondent By : Ms. Anitha, Addl.Cit सुनवाईकीतारीख/Date Of Hearing : 04.04.2025 घोषणाकीतारीख / Date Of Pronouncement : 06.06.2025 :: 2 ::

For Appellant: Mr. V. Balaji, CA &For Respondent: Ms. Anitha, Addl.CIT

Section 11Section 12ASection 139(1)Section 143(1)Section 270ASection 271A

St. Josephs Institute of Science and Technology Trust, Chennai vs. Dcot. Central Circle-1(3), Chennai

In the result, all the appeals filed by the assessees are allowed

ITA 3295/CHNY/2024[2018-19]Status: DisposedITAT Chennai06 Jun 2025AY 2018-19

Bench: Shri Aby T. Varkey & Shri Jagadish

For Appellant: Mr. V. Balaji, CA &For Respondent: Ms. Anitha, Addl.CIT

Section 11Section 12ASection 139(1)Section 143(1)Section 270ASection 271A

declaring gross receipts of Rs.43,78,72,937/- and ‘Nil’ taxable income and had shown in its books of accounts that it has received corpus donation of Rs.5,88,60,300/- by way of Demand Draft (DD) which RoI was processed u/s.143(1) of the Act and the same ... amount of shortfall in the application of funds to the extent of 85% of the income [including corpus donation which was treated as voluntary donations] received during the relevant previous year in accordance with section 11 of the Act. The AO is noted to have passed the assessment order u/s.153A

St. Josephs Educational Trust, Chennai vs. DCIT, Central Circle-193), Chennai

ITA 3294/CHNY/2024[2020-21]Status: DisposedITAT Chennai06 Jun 2025AY 2020-21

Bench: Shri Aby T. Varkey & Shri Jagadishआयकर अपील सं./Ita Nos.3293 & 3294/Chny/2024 निर्धारणवर्ष/Assessment Year: 2018-19 & 2020-21 St. Joseph'S Educational Trust, 56-C, Old Mahabalipuram Road, Sholinganallur, Chennai-600 119. [Pan: Aamts 3888 G] (अपीलार्थी/Appellant) V. The Dcit, Central Circle-1(3), Chennai. (प्रत्यर्थी/Respondent) आयकर अपील सं./Ita Nos.3295 To 3297/Chny/2024 निर्धारणवर्ष/Assessment Year: 2018-19 To 2020-21 St. Joseph'S Institute Of Science & Technology Trust, 56-C, Old Mahabalipuram Road, Sholinganallur, Chennai-600 119. [Pan: Aahts 9943 B] (अपीलार्थी/Appellant) V. The Dcit, Central Circle-1(3), Chennai. (प्रत्यर्थी/Respondent) अपीलार्थी की ओर से/ Appellant By : Mr. V. Balaji, Ca & Mr. K.R. Vasudevan, Advocate By Virtual प्रत्यर्थी की ओर से /Respondent By : Ms. Anitha, Addl.Cit सुनवाईकीतारीख/Date Of Hearing : 04.04.2025 घोषणाकीतारीख / Date Of Pronouncement : 06.06.2025 :: 2 ::

For Appellant: Mr. V. Balaji, CA &For Respondent: Ms. Anitha, Addl.CIT

Section 11Section 12ASection 139(1)Section 143(1)Section 270ASection 271A

St.Josephs Educational Trust, Chennai vs. DCIT, Central Circle-193), Chennai

In the result, all the appeals filed by the assessees are allowed

ITA 3293/CHNY/2024[2018-19]Status: DisposedITAT Chennai06 Jun 2025AY 2018-19

Bench: Shri Aby T. Varkey & Shri Jagadish

For Appellant: Mr. V. Balaji, CA &For Respondent: Ms. Anitha, Addl.CIT

Section 11Section 12ASection 139(1)Section 143(1)Section 270ASection 271A

M/S Surya World Educational Research and Charitable Institute, Rajpura vs. DCIT, CC-I, Chandigarh

In the result, the appeal filed by the assessee is dismissed both for non-

ITA 880/CHANDI/2018[2012-13]Status: DisposedITAT Chandigarh03 Jun 2025AY 2012-13

For Appellant: NoneFor Respondent: Smt. Kusum Bansal, CIT, DR (Virtual Mode)

Section 68

assessee filed an application under Rule 46A of the Income Tax Rules, 1962, for admission of additional evidence relating to corpus donations and unsecured loans. The Ld. CIT(A) forwarded the additional evidence to the Assessing Officer for a remand report. The AO submitted a report dated 22 October ... settled that mere furnishing of confirmation or general explanations without credible supporting evidence is not sufficient to discharge the burden. 7. In respect of corpus donations, we note that the assessee has not submitted proper documentation evidencing the identity of the donors. In terms of section 115BBC

M/S Surya World Educational Research and Charitable Institute, Rajpura vs. DCIT, CC-I, Chandigarh

In the result, the appeal filed by the assessee is dismissed both for non- prosecution and on merits

ITA 879/CHANDI/2018[2011-12]Status: DisposedITAT Chandigarh03 Jun 2025AY 2011-12

Bench: Us. Therefore, For The Sake Of Convenience & To Avoid Repetition, We Are Taking Ita No. 879/Del/2018 As The Lead Appeal & Reproducing The Facts, Grounds Raised & The Order Passed By The Ld. Cit(A)Karnal, For Completeness. 2. The Case Was Listed For Hearing On 29/5/2025 , When The Matter Was Called, There Was No Appearance From The Side Of The Assessee. It Is Noted From The Record That Earlier Mr. Tej Mohan, Advocate, Was Appearing On Behalf Of The Assessee. However, No Adjournment Request Or Explanation For Non-Appearance Has Been Filed. The Conduct Of The Assessee Indicates A Lack Of Interest In Prosecuting The Appeal. However, Considering Non- Appearance On Behalf Of The Assessee On Many Earlier Occasions & The Nature Of The Issues Involved, We Proceed To Decide The Appeal On Merits As Well.

For Appellant: NoneFor Respondent: Smt. Kusum Bansal, CIT, DR (Virtual Mode)

Section 68

M/S Surya World Educational Research and Charitable Institute, Rajpura vs. DCIT, CC-I, Chandigarh

In the result, the appeal filed by the assessee is dismissed both for non- prosecution and on merits

ITA 878/CHANDI/2018[2010-11]Status: DisposedITAT Chandigarh03 Jun 2025AY 2010-11

For Appellant: NoneFor Respondent: Smt. Kusum Bansal, CIT, DR (Virtual Mode)

Section 68

Akhil Bhartiya Brahmkshtriy Dharamshala Trust, Ramdeora, Pokaran vs. ITO, Exemption, Jodhpur

In the result, the appeal of the assessee bearing ITA No

ITA 244/JODH/2024[2019-20]Status: DisposedITAT Jodhpur29 May 2025AY 2019-20

Bench: BEFOREDR. MITHA LAL MEENA (Accountant Member), SHRI ANIKESH BANERJEE (Judicial Member)

Section 11(1)(d)Section 12ASection 143(3)Section 234ASection 250

natural justice and before remand report was provided the appellate order was made. 2. The Id. CIT(A) has erred in considering the corpus donation received of Rs. 3,50,000/-as income of the assessee which was capital receipt u/s 11(1)(d) The addition so sustained ... kept on record. The Ld.AR, in argument, placed that the assessee is a charitable trust and during the impugned assessment year assessee received corpus donation of Rs.3,50,000/- which added to the total income of the assessee, by the Ld.AO and confirmed by the Ld.CIT(A). Also the income