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“corpus fund”

Charitable TrustsSection 11(1)(d)Section 11(1)(d)337 judgments

B R MORDEM SCHOOL SAMITI,PAURI vs. I T O, EXEMPTION WARD DEHRADUN, DEHRADUN

In the result, the appeal of the assessee is allowed

ITA 27/DDN/2026[2016-17]Status: DisposedITAT Dehradun13 Mar 2026AY 2016-17
Section 10Section 12ASection 143(3)Section 148Section 250

nsubmitted that the receipts of the society are only\nRs.60,24,857/- and an amount of Rs.39,14,102/- was\nreceived as donation towards corpus fund. The AO held\nthat the receipts of the society exceeded Rs.1.00 Crore\nand therefore exemption u/s 10(23C)(iiiad) is not\nallowed

SHRI AJAY MAYOR,,AHMEDABAD vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1(2),, AHMEDABAD

In the result, the appeal of the assessee is allowed

ITA 1607/AHD/2019[2013-14]Status: DisposedITAT Ahmedabad13 Mar 2026AY 2013-14

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

For Appellant: Shri S. N. Soparkar, Sr. Adv. &For Respondent: Shri C Dharani Nath, Sr. DR
Section 271(1)(c)Section 274

case of Dwarka Prasad v ITO in ITA Number 4591 and 4592/Mum/2016 vide order dated 05.10.2017 wherein Mumbai ITAT held that distribution out of corpus funds is a capital receipt not liable to tax in the hands of the assessee. The reference to Special Bench of the ITAT

NEW HOPE SOCIETY,BERHAMPUR vs. ITO EXEMPTION, BERHAMPUR

In the result, this appeal of the assessee is dismissed

ITA 44/CTK/2026[2016-17]Status: DisposedITAT Cuttack23 Feb 2026AY 2016-17

Bench: Shri George Mathan & Shri Madhusudan Sawdianew Hope Society, I.T.O., C/O- New Hope Society Main Road, Exemption Ward, Vs. Hillpatna, Berhampur-760005 (Odisha) Berhampur. Pan No. Aabtn 1122 D Appellant/ Assessee Respondent/ Revenue

show that the persons who have given the development fees have desired that the development fees is to be taken to the corpus fund. In fact, a perusal of the break up of the development fees collected, shows that the fixed amount has been collected from the students

DCIT CENTRAL CIRCLE 7 (1) , MUMBAI vs. DR D Y PATIL EDUCATIONAL ACADEMY, MUMBAI

In the result, both the appeals filed by the revenue are dismissed

ITA 2289/MUM/2025[2015-16]Status: DisposedITAT Mumbai10 Feb 2026AY 2015-16

Bench: Hon’Ble Shri Sandeep Gosain & Shri Girish Agrawal

Section 12ASection 132Section 132(4)Section 153Section 250

compulsory charge on the students then the same cannot be classified as capital in nature for specific purpose or part of the corpus fund of the assessee Trust. 7. Whereas on the contrary it was submitted by the assessee that the intention of contribution of development fee is for utilizing ... education research, education infrastructure, library, sports, staff welfare and students welfare. Parents/students had made contribution with a clear understanding that contributions were towards different corpus funds. Furthermore, trust deed stipulated that voluntary contributions given by parents/students for furtherance of objects of trust were exclusive property of trust which were required

DCIT CENTRAL CIRCLE 7 (1) , MUMBAI vs. DR D Y PATIL EDUCATIONAL ACADEMY, MUMBAI

In the result, both the appeals filed by the revenue are dismissed

ITA 2251/MUM/2025[2017-18]Status: DisposedITAT Mumbai10 Feb 2026AY 2017-18

Bench: Hon’Ble Shri Sandeep Gosain & Shri Girish Agrawal

Section 12ASection 132Section 132(4)Section 153Section 250

compulsory charge on the students then the same cannot be classified as capital in nature for specific purpose or part of the corpus fund of the assessee Trust. 7. Whereas on the contrary it was submitted by the assessee that the intention of contribution of development fee is for utilizing ... education research, education infrastructure, library, sports, staff welfare and students welfare. Parents/students had made contribution with a clear understanding that contributions were towards different corpus funds. Furthermore, trust deed stipulated that voluntary contributions given by parents/students for furtherance of objects of trust were exclusive property of trust which were required

UTTAR PRADESH DIPLOMA ENGINEERS MAHASANGH,LUCKNOW vs. DY/ASSISTANT COMMISSIONER OF INCOME TAX-1, LUCKNOW

In the result, all the appeals are partly allowed for statistical purposes

ITA 425/LKW/2025[2016-17]Status: HeardITAT Lucknow05 Feb 2026AY 2016-17

Bench: Shri Kul Bharat & Shri Anadee Nath Misshra

Section 28Section 56Section 71

dated 15/07/2024 (referred to in foregoing paragraph B.2 of this order) the assessee has specifically submitted that the enrollment fee, forming part of the corpus fund of the association, was not considered by the learned CIT(A) in the impugned appellate order and has escaped his attention. Moreover, the claim

INCOMETAX OFFICER EXEMPTIONS WARD, TIRUNELVELI vs. AARK INDIA EDUCATIONAL CHARITABLE TRUST, TIRUNELVELI

In the result, the appeal of the asse

ITA 2387/CHNY/2025[2012-13]Status: DisposedITAT Chennai04 Feb 2026AY 2012-13

Bench: Shri Manu Kumar Giri & Shris.R.Raghunathaआयकरअपीलसं/.Ita Nos.: 1986/Chny/2025 "नधा"रणवष" / Assessment Year: 2012-13 Aark India Educational V. Income Tax Officer Charitable Trust, (Exemptions Ward) Nellai 1 1 Francis Xavier Engineering City Centre, Rahmath Nagar, College Campus, Vannarapettai, Tiruchendur Road, Tirunelveli, Tamil Nadu Tirunelveli Tamil Nadu- 627003 627011 [Pan: Aacta 2809 D] (अपीलाथ /Appellant) (!"यथ /Respondent) आयकरअपीलसं/.Ita No. 2387/Chny/2025 (Revenue Appeal) "नधा"रणवष" / Assessment Year: 2012-13 Income Tax Officer (Exemptions Aark India Educational Ward) Nellai City Centre, Rahmath Charitable Trust, Nagar, Tiruchendur Road, 1 1 Francis Xavier Tirunelveli Tamil Nadu-627011 Engineering College Campus, Vannarapettai, Tirunelveli, Tamil Nadu-627003 [Pan: Aacta 2809 D] (अपीलाथ /Appellant) (!"यथ /Respondent) अपीलाथ क$ओरसे/Appellant/Assessee By : Mr. Y. Sridhar, F.C.A. : Ms. E. Pavuna Sundari, Cit !"यथ क$ओरसे/Respondent/Revenue By सुनवाईक$तार"ख/Date Of Hearing : 07.01.2026

For Appellant: Mr. Y. Sridhar, F.C.A
Section 12ASection 133A

after repayment of Rs.5,56,982/- the remaining amount of the remaining amount of Rs.6,19,11,861 1,861/- was converted into corpus funds. converted into corpus funds. 5. The eight individuals from whom the advances were received, as The eight individuals from whom the advances were received

M/S. AARK INDIA EDUCATIONAL TRUST,TIRUNELVELI vs. ITO (EXEMPTIONS), TIRUNELVELI

In the result, the appeal of the asse

ITA 1986/CHNY/2025[2012-13]Status: DisposedITAT Chennai04 Feb 2026AY 2012-13

Bench: Shri Manu Kumar Giri & Shris.R.Raghunathaआयकरअपीलसं/.Ita Nos.: 1986/Chny/2025 "नधा"रणवष" / Assessment Year: 2012-13 Aark India Educational V. Income Tax Officer Charitable Trust, (Exemptions Ward) Nellai 1 1 Francis Xavier Engineering City Centre, Rahmath Nagar, College Campus, Vannarapettai, Tiruchendur Road, Tirunelveli, Tamil Nadu Tirunelveli Tamil Nadu- 627003 627011 [Pan: Aacta 2809 D] (अपीलाथ /Appellant) (!"यथ /Respondent) आयकरअपीलसं/.Ita No. 2387/Chny/2025 (Revenue Appeal) "नधा"रणवष" / Assessment Year: 2012-13 Income Tax Officer (Exemptions Aark India Educational Ward) Nellai City Centre, Rahmath Charitable Trust, Nagar, Tiruchendur Road, 1 1 Francis Xavier Tirunelveli Tamil Nadu-627011 Engineering College Campus, Vannarapettai, Tirunelveli, Tamil Nadu-627003 [Pan: Aacta 2809 D] (अपीलाथ /Appellant) (!"यथ /Respondent) अपीलाथ क$ओरसे/Appellant/Assessee By : Mr. Y. Sridhar, F.C.A. : Ms. E. Pavuna Sundari, Cit !"यथ क$ओरसे/Respondent/Revenue By सुनवाईक$तार"ख/Date Of Hearing : 07.01.2026

For Appellant: Mr. Y. Sridhar, F.C.A
Section 12ASection 133A

after repayment of Rs.5,56,982/- the remaining amount of the remaining amount of Rs.6,19,11,861 1,861/- was converted into corpus funds. converted into corpus funds. 5. The eight individuals from whom the advances were received, as The eight individuals from whom the advances were received

SREE MARUTHI CO-OPERATIVE HOUSING SOCIETY,BANGALORE, KARNATAKA vs. ITO WARD 7(2)(2), BANGALORE, BANGALORE, KARNATAKA

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

ITA 2164/BANG/2024[2017-18]Status: DisposedITAT Bangalore03 Feb 2026AY 2017-18

Bench: Shri Prashant Maharishi, Vice – & Shri Soundararajan K.Assessment Year : 2017-18

For Appellant: Shri P.R. Suresh, CAFor Respondent: Shri Subramanian .S, JCIT-DR
Section 142(1)Section 143(1)Section 143(2)Section 143(3)Section 80PSection 80P(2)(a)Section 80P(2)(d)Section 80P(4)

assessee before this Tribunal. 4. At the time of hearing, the assessee submitted that the assessee is a co-operative society and deposited its corpus funds collected from the members with the co-operative banks and earned interest out of the said deposits and therefore the co-operative banks being ... societies, the said interest income is entitled for deduction u/s. 80P of the Act. The Ld.AR also submitted an alternate argument that since the corpus fund was deposited into the co-operative bank the interest accrued from the said deposits could be treated as capital in nature and therefore

JAINACHARYA DEVENDRA MUNI SHIKSHAN AND CHIKITSA SHODH SANSTHAN,UDAIPUR vs. ADIT, CPC, BENGALURU / ITO, EXEMPTION WARD, , UDAIPUR

The appeal is allowed for statistical purpose

ITA 256/JODH/2025[2016-17]Status: DisposedITAT Jodhpur28 Jan 2026AY 2016-17

Bench: Dr. Mitha Lal Meena, Hon’Ble & Shri Sudhir Pareek, Hon’Blejainacharya Devendra Muni Adit, Cpc, Bengaluru/ Ito Shikshan & Chikitsa Shodh Exemption Ward Sansthan Udaipur - 313001 N H 8-1 (4) Bhuwana Udaipur (Raj) - 313001 Pan No. Aaatj 5263 G Assessee By Shri Yogesh Pokharna, C.A. (Physical) Shri K.C. Meena, Addl. Cit-Dr (Virtual) Revenue By Date Of Hearing 13.01.2026. Date Of Pronouncement 28.01.2026. Order Dr. Mitha Lal Meena, A.M.: The Appeal Is Filed By The Assessee Against The Order Of The Ld. Commissioner Of Income Tax, Appeal, Addl/Jcit (A)-1 Visakhapatnam [Hereinafter Referred To As “The Jcit Appeal”] Dated 05.03.2025 With Respect To Assessment Year 2016-17 Challenging Therein Disallowance Of Capital Expenditure Amounting To Rs. 24,75,863/- In Corpus Fund Of Rs. 6,09,448/- Without Appreciating The Merits Of The Case.

Section 11(2)Section 139(1)Section 139(4)Section 250

JCIT appeal”] dated 05.03.2025 with respect to assessment year 2016-17 challenging therein disallowance of capital expenditure amounting to Rs. 24,75,863/- in corpus fund of Rs. 6,09,448/- without appreciating the merits of the case. 2. Having heard both the sides and perusal of the record

THE FALAHE DARAIN EDUCATION SOCIETY,AHMEDABAD vs. DCIT, CIRCLE-1, EXMP., AHMEDABAD, AHMEDABAD

In the result, appeal filed by the assessee is allowed

ITA 2111/AHD/2025[2016-17]Status: DisposedITAT Ahmedabad27 Jan 2026AY 2016-17

Bench: SMT. ANNAPURNA GUPTA (Accountant Member), SHRI T.R. SENTHIL KUMAR (Judicial Member)

For Appellant: Shri Sunil Talati, A.RFor Respondent: Smt. Ananya Kulshresth, Sr.DR
Section 11(1)(d)Section 12ASection 250Section 69ASection 80G

failed to establish the identity of the actual donors and no written direction from any donor specifying that the amount is for corpus fund had been produced. Ld.CIT(A) held so after considering the remand report of the AO and the submissions filed by the assessee to him. His findings ... donations were collected by students without maintaining donor details. No written direction from any donor specifying that the amount is for the corpus fund has been produced. Merely classifying a receipt as "corpus" in the internal books does not meet the statutory requirement. Even for foreign contributions, no donor correspondence

DEPUTY COMMISSIONER OF INCOME TAX (EXEMPTIONS) , CHENNAI vs. THE ICICI FOUNDATION FOR INCLUSIVE GROWTH , MUMBAI

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

ITA 2386/CHNY/2025[2012-13]Status: DisposedITAT Chennai20 Jan 2026AY 2012-13

Bench: Hon’Ble Shri Manu Kumar Giri & Before Hon’Ble Shri Manu Kumar Giri & Before Hon’Ble Shri Manu Kumar Giri & Before Hon’Ble Shri Manu Kumar Giri & Shri S.R. Raghunathashri S.R. Raghunathashri S.R. Raghunathashri S.R. Raghunathaआयकर आयकर अपील आयकर आयकर अपील अपील संसंसंसं././././Ita No.2 अपील

For Appellant: Mr. S.Sriram, AdvocateFor Respondent: Ms. E.Pavuna Sundari, CIT
Section 11(1)(d)Section 12ASection 80G

action of the Ld.CIT(A) in deleting the addition of Rs.19,34,72,836/- made by the Assessing Officer by treating withdrawal from corpus fund as income of the assessee and also deleting the ad-hoc disallowance of administrative expenses amounting to Rs.5,30,70,160/- made by the Assessing ... exempt u/s.11(1)(d) of the Act. However, he observed that the assessee had withdrawn an amount of Rs.19,34,72,836/- from the corpus fund to meet expenditure during the year. According to the Assessing Officer, the administrative expenditure had increased substantially as compared to the earlier year

BLIND PEOPLES ASSOCIATION INDIA,AHMEDABAD vs. THE DY.CIT, CIRCLE-1(EXEMPTION), AHMEDABAD

In the result, the appeal of the assessee is allowed

ITA 1959/AHD/2025[2016-17]Status: DisposedITAT Ahmedabad07 Jan 2026AY 2016-17

Bench: Dr. Brr Kumar & Ms. Suchitra Kambleassessment Year 2016-17

For Appellant: Shri Nitin Pathak, A.RFor Respondent: Shri Amit Pratap Singh, Sr. D.R
Section 143(3)

Officer has not taken into account the detailed entries along with receipts which are filed before us demonstrate that the donations were for the corpus fund only and therefore the Assessing Officer as well as CIT(A) was not right in confirming the addition to the extent

INCOME TAX OFFICER(E) WARD- 2(4), NEW DELHI, CIVIC CENTRE NEW DELHI vs. PRAKASH SEWA TRUST, PASCHIM VIHAR

In the result, the appeal of the Revenue is dismissed

ITA 4305/DEL/2024[2016-17]Status: DisposedITAT Delhi07 Jan 2026AY 2016-17
Section 11Section 12ASection 143(3)

some organization. It may not\nbe out of place to mention that many of the organizations to whom the money was\ngiven had received corpus funds from established entry operators, For example, as\nper the information circulated by the Investigation wing of the Department, Sangneria\nFoundation for Health and Education

BAHBUDI FUND SANCHALAN SAMITI,KANPUR vs. INCOME TAX OFFICER-, A

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

ITA 731/LKW/2025[2021-22]Status: DisposedITAT Lucknow31 Dec 2025AY 2021-22

Bench: Shri. Sudhanshu Srivastavaassessment Year: 2021-22 Bahbudi Fund Sanchalan Samiti V. The Ito-A Gt Road, Sarvodaya Nagar, Hns Nagar S.O Kanpur Nagar (U.P) Tan/Pan:Aadtb9409M (Applicant) (Respondent) Applicant By: None Respondent By: Shri R.R.N. Shukla, D.R. O R D E R This Appeal Has Been Preferred By The Assessee Against The Order Dated 11.08.2025, Passed By The Addl/Jcit(A)-7, Delhi For Assessment Year 2021-22. 2.0 The Brief Facts Of The Case Are That The Assessee-Samiti Filed Its Return Of Income For The Year Under Consideration On 31.03.2024 Declaring A Total Income Of Rs.22,39,055/-. The Centralized Processing Centre (Cpc), Bangalore Processed The Return Under Section 143(1) Of The Income Tax Act, 1961 (Hereinafter Called “The Act’) & Vide Intimation/Order Dated 04.12.2024 Made Addition/Raised A Demand Of Rs.7,72,970/-.

For Respondent: Shri R.R.N. Shukla, D.R
Section 143(1)Section 249(3)Section 250

That no Income has arisen as this a government fund because money is received from U.P government through the governor of U.P. 5. The corpus fund is to be set aside and the welfare scheme is to be initiated from the interest earned. This is meant for the welfare

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

amount of corpus receipt declared in the returnof income for Rs. 50,60,49,193/- was difference between opening and closing balance of corpus fund. Hence, the AO disallowed the claim of exemption for Rs. 50,60,49,193/- and added the same to the total income of the assessee ... Jurisdictional Assessing Officer with regard to additional submissions of assessee, and the reply dated 5/6/2023 has also been considered. Following are the issues: 4.1 Corpus Fund Donations treated as Income - Rs.50,60,49,193/-: Assessee vide responses dated 17/11/2022 has submitted to AO that there were clerical errors while filing

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

observed from the submission of the appellant dated 28-03-2018 that the appellant demonstrated the real nature of receipt was donation corpus fund being applied in the construction of Dharmshala and Satsang Hall at Vrindavan for providing shelter to pilgrims. It was also stated in the said submission since

GAMMON NEELKANTH REALTY CORPORATION,MUMBAI, MAHARASHTRA vs. DY. COMMISSIONER OF INCOME TAX, CIRCLE 27(1), MUMBAI, NAVI MUMBAI, MAHARASHTRA

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

ITA 6239/MUM/2025[2016-2017]Status: DisposedITAT Mumbai11 Dec 2025AY 2016-2017

Bench: Smt. Beena Pillai () & Girish Agrawal ()

Section 143(3)Section 37(1)

Income Tax (Appeals), NFAC has erred in law and on facts in upholding the action of Ld. Assessing Officer in adding the interest on corpus fund of society of Rs 60,21,474/-to the total income on conjectures and surmises which is unwarranted and unlawful despite the fact that

HARYANA BUILDING AND OTHER CONSTRUCTION WORKERS WELFARE BOARD,PANCHKULA vs. DCIT, EXEMPTION, SECTOR 17

In the result, this appeal of the Assessee stands dismissed

ITA 339/CHANDI/2023[2018-2019]Status: DisposedITAT Chandigarh10 Dec 2025AY 2018-2019
For Appellant: \nSh. Nikhil Goyal, AdvocateFor Respondent: Sh. Manav Bansal, CIT DR
Section 263

funds.\n4. 8. Thus, the cess collected does not vest in the Board as its income or\nrevenue receipt, but rather as an earmarked corpus fund, held in fiduciary\ncapacity for the benefit of registered workers. It is a settled principle of\nlaw that receipts which are statutorily earmarked ... utility purposes are not liable to be treated as\nhaving earned taxable income, as the amounts so collected partake the\nnature of trust or corpus funds.\n4. 9. Accordingly, the cess collections of the appellant-Board are basically\nlinked to its statutory obligation and welfare objects, and therefore, must

HARYANA BUILDING AND OTHER CONSTRUCTION WORKERS WELFARE BOARD,PANCHKULA vs. DCIT, EXEMPTION, CHANDIGARH

In the result, this appeal of the Assessee stands dismissed

ITA 338/CHANDI/2023[2017-2018]Status: DisposedITAT Chandigarh10 Dec 2025AY 2017-2018
For Appellant: Sh. Nikhil Goyal, AdvocateFor Respondent: Sh. Manav Bansal, CIT DR
Section 263

Thus, the cess collected does not vest in the Board as its income or\nrevenue receipt, but rather as an earmarked corpus fund, held in fiduciary\n21\n\ncapacity for the benefit of registered workers. It is a settled principle of\nlaw that receipts which are statutorily earmarked for application ... utility purposes are not liable to be treated as\nhaving earned taxable income, as the amounts so collected partake the\nnature of trust or corpus funds.\n\n4. 9. Accordingly, the cess collections of the appellant-Board are basically\nlinked to its statutory obligation and welfare objects, and therefore, must

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