“corpus fund”

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

The decision most relied on for corpus fund is CIT v. Shri Plot Swetamber Murti Pujak Jain Mandal (211 ITR 293), cited in 204 judgments on BharatTax.

Leading authorities on corpus fund

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

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).

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. Halai Namon Association (

330 ITR 24 · 2011 · High Court

citing judgments

Profits generated from activities for the advancement of a general public utility (GPU) do not automatically qualify for exemption under Section 11 if the GPU is carried on as a business. Even if business profits are reinvested into charitable activities, the exemption under Section 11 will not be available.

New Life in Christ Evangelistic Association v. CIT

246 ITR 532 · 2000 · High Court

citing judgments

Before registration is granted under section 12AA, all voluntary contributions, even those designated as corpus funds, are considered income of the charitable or religious trust.

CIT v. Trustees of Kasturbai Scindia Commission Trust

189 ITR 5 · 1991 · High Court

citing judgments

Voluntary contributions specifically received towards the corpus of a trust cannot be brought to tax as income. Funds created for specific objectives remain capital funds and are not to be pooled with normal income.

Provat Kumar Mitter v. CIT

41 ITR 624 · 1961 · Supreme Court

citing judgments

Receipts stand diverted by an overriding title where an obligation to pay an amount is attached to the very source of income, rather than being a mere application of income.

Judgments citing corpus fund

Gurjar Kalyan Parishad, Palwal vs. CIT(Exemption), Chandigarh

In the result, the Appeal of the assessee is dismissed

ITA 1247/DEL/2018[-]Status: DisposedITAT Delhi13 Sept 2023

Bench: us, in view of the same, we are constrained to decide the appeal after hearing the Ld. Departmental Representative and on perusal of the material available on record.

Section 12ASection 80GSection 80I

addition in the capital fund by accumulating corpus donations which were shown in the Receipt and Payment accounts and applicant is continuously reducing its corpus fund by deducting its Deficit i.e Excess of Expenditure over income. Given the fact that the corpus fund is a fund which could be disturbed

Shri Krishna Das Jajoo Smarak Trust, Delhi vs. ITO, Ward Exemp. 2(2), Delhi

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

ITA 1417/DEL/2022[2016-17]Status: DisposedITAT Delhi30 Aug 2023AY 2016-17

Bench: filing the return. Aggrieved by the order dated 25/01/2019 passed u/s 154 of the Act, the assessee preferred an Appeal before the CIT(A). The Ld. CIT(A) vide order dated 18/04/2022, dismissed the Appeal filed by the assessee by confirming the Shri Krishna Das Jajoo Smarak Trust vs. ITO

Section 11Section 11(1)Section 12ASection 143(1)Section 154

allowing the actual expenses incurred on the object of the trust of Rs. 44,64,200 and treated the donation received for corpus fund of Rs. 1.50,000 as income without assigning any reason and erred in upholding the disallowance made by AO. 4. The appellant craves in lieu

Yadav Kalyan Samiti, Faridabad vs. CIT Exmptions Chandigarh, Chandigarh

Appeal of the assessee is allowed for statistical purposes

ITA 2052/DEL/2021[2021-22]Status: HeardITAT Delhi30 Aug 2023AY 2021-22

Bench: Shri Narendra Kumar Billaiya & Shri Kul Bharatassessment Year: 2021-22

Section 11Section 12ASection 2(15)

under: “6. After considering the submissions on record, it is observed that the applicant has shown an amount of Rs. 5,51,000/- as Corpus Fund in its Balance Sheet for F.Y. 2016-17 and Rs. 11,00,000/- for F.Y. 2Q'\7-18 in the name of specific donation ... 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 fund shown by the applicant on record during FY 2016-17 and 2017-18 (and for any other previous year) is the income

Gujrati Mahamandal Hati Bhata, Ajmer vs. Income Tax Officer (Exemption), Ajmer

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

ITA 810/JPR/2018[2013-14]Status: DisposedITAT Jaipur24 Aug 2023AY 2013-14

Bench: SHRI SANDEEP GOSAIN (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri Ankur Saliga, CAFor Respondent: Smt. Monisha Choudhary, JCIT-DR

Section 10Section 11

Below) was quite unreasonable and unjustified. 3. That the addition an account of development fees for Rs. 881362.50 was wrong as it is a corpus fund for building construction cannot become part of Income as it is capital assets and will be used in development of Building Constructions ... AJMER donation. The assessee has not produced any evidence to show that 50% of development was the donation received with the specific direction for corpus fund. Therefore, the addition of Rs.8,81,362/- is hereby confirmed.’’ 4.2 During the course of hearing, the ld. AR of the assessee

The Press Club of Odisha, Bhubaneswar vs. ITO (Exemption) Ward, Bhubaneswar

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

ITA 179/CTK/2022[2014-15]Status: HeardITAT Cuttack23 Aug 2023AY 2014-15

Bench: Before S/Shri George Mathan, Judicial & And Rajesh Kumarassessment Year : 2014-15 The Press Club Of Odisha, The Press Club Of Odisha, Vs. Income Income Tax Tax Officer Officer Qr. No.Vii Ds1/1, Master Qr. No.Vii Ds1/1, Master (Exemptions), (Exemptions), Ward, Ward, Canteen Canteen Square, Square, Unit Unit-Iii, Bhubaneswar. Bhubaneswar. Bhubaneswar. Bhubaneswar. Pan/Gir No. Pan/Gir No.Aactt 3137 H (Appellant (Appellant) .. ( Respondent Respondent) Assessee By : Shri D.Parida, Ca D.Parida, Ca Revenue By : Shri S.C.Mohanty, Sr Dr : Shri S.C.Mohanty, Sr Dr Date Of Hearing : 23/08 8/2023 Date Of Pronouncement : 23/0 /08/2023 O R D E R Per Bench This Is An Appeal Filed By The Assessee Aga This Is An Appeal Filed By The Assessee Against The Order Of The Ld Inst The Order Of The Ld Cit(A), Cit(A), Nfac, Nfac, Delhi, Delhi, Dated 23.10.2022 In Appeal No. Itba/Nfac/S/250/2022 Itba/Nfac/S/250/2022-23/1046453146(1) For The Assessment Year For The Assessment Year 2014- 15. 2. Shri D.Parida, Ca Appeared For The Assessee & Shri S.C.Mohanty, Ld Shri D.Parida, Ca Appeared For The Assessee & Shri S.C.Mohanty, Ld Shri D.Parida, Ca Appeared For The Assessee & Shri S.C.Mohanty, Ld Sr Dr Appeared For The Revenue. Sr Dr Appeared For The Revenue.

For Appellant: Shri D.Parida, CAFor Respondent: Shri S.C.Mohanty, Sr DR

Section 143(1)Section 154

application u/s.154 of the Act P a g e 1 | 3 Assessment Year : 2014-15 by the AO without adjudicating the fact that the corpus fund contributed by the club members of Rs.56,10,000/- is exempted from tax on the doctrine of mutuality. It was the submission that

Shri Osham Jain Temple Trust, Rajkot, at . Patanvav, Taluka Dhoraji, Dist. Rajkot vs. The CIT-(Exemptions), Ahmedabad

In the result, the matter is being set-aside to the file of the CIT(E) with the aforesaid directions

ITA 116/RJT/2021[2015-16]Status: DisposedITAT Rajkot23 Aug 2023AY 2015-16

Bench: Shri Waseem Ahmed & Shri Siddhartha Nautiyal

For Appellant: Shri Darshak Thakkar, A.RFor Respondent: Shri Shramdeep Sinha, CIT DR

Section 11Section 11(1)(d)Section 143(3)Section 263

Ahmedabad is invalid and dead in law. 2. That the learned Commissioner of Income Tax (Exemptions), Ahmedabad ought to have allowed the claim of corpus fund of Rs. Shri Osham Jain Temple Trust vs. CIT(E) Asst.Year –2015-16 26615497/- u/s 11(1)(d) of the Income

Sahachari Foundation, New Delhi vs. ITO Ward 2(1) Exemption, New Delhi

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

ITA 534/DEL/2023[2017-18]Status: DisposedITAT Delhi17 Aug 2023AY 2017-18

Bench: Shri N.K. Billaiya & Shri Yogesh Kumar U.S

For Appellant: Shri K.V.S.R. Krishana, AdvFor Respondent: Shri H.K. Choudhary, CIT- DR

Section 11Section 12Section 263

dispute that during the course of assessment proceedings itself, the assessee was asked to provide details of expenditure out of corpus fund of Rs.41 lakhs, and it is also not in dispute that on perusal of the details, submitted by the assessee, the Assessing Officer found that the assessee ... which has made the assessment order erroneous in law. Since there is a revenue leakage in so far as utilization of corpus fund of Rs. 41 lakhs, the assessment order is also prejudicial to the interest of the revenue. 18. Considering the facts in totality, we do not find

Infoparks Kerala, Cochin vs. The ACIT, Cochin

In the result, the assessee’s appeals are partly allowed

ITA 77/COCH/2015[2011-12]Status: DisposedITAT Cochin11 Aug 2023AY 2011-12

Bench: Shri Sanjay Arora, Am & Shri Aby T. Varkey, Jm

For Appellant: Sri. Rajakannan, AdvocateFor Respondent: Smt. J.M. Jamuna Devi, Sr.AR

Section 11Section 11(1)Section 12ASection 143(3)Section 2(15)

fixed deposits with Interest 760.32 738.81 523.33 banks credited Total surplus (2) 846.41 887.21 702.96 directly to the Stated turnover 901.45 1004.38 1157.98 corpus fund, duly Interest 760.32 738.81 523.33 reported to the Total turnover 1661.77 1743.19 1681.31 Revenue per the (2) returns of income

Infoparks Kerala, Trivandrum vs. The Jt Director of It (OSD) Exem), Cochin

In the result, the assessee’s appeals are partly allowed

ITA 76/COCH/2015[2010-11]Status: DisposedITAT Cochin11 Aug 2023AY 2010-11

Bench: Shri Sanjay Arora, Am & Shri Aby T. Varkey, Jm

For Appellant: Sri. Rajakannan, AdvocateFor Respondent: Smt. J.M. Jamuna Devi, Sr.AR

Section 11Section 11(1)Section 12ASection 143(3)Section 2(15)

Infoparks Kerala, Trivandrum vs. The Jt Director of It (OSD) Exem), Cochin

In the result, the assessee’s appeals are partly allowed

ITA 75/COCH/2015[2009-10]Status: DisposedITAT Cochin11 Aug 2023AY 2009-10

Bench: Shri Sanjay Arora, Am & Shri Aby T. Varkey, Jm

For Appellant: Sri. Rajakannan, AdvocateFor Respondent: Smt. J.M. Jamuna Devi, Sr.AR

Section 11Section 11(1)Section 12ASection 143(3)Section 2(15)

Middle Income Group Co-Op Hsg. Soc. Ltd, Mumbai vs. Income Tax Officer, Ward-23(2)(3), Mumbai

ITA 541/MUM/2023[2016-2017]Status: DisposedITAT Mumbai27 Jul 2023AY 2016-2017

Bench: Shri Amit Shukla & Shri Gagan Goyal & Middle Income Group Co. Op. Hsg. Soc. Ltd, Behind Bldg. No. D-17, Gandhi Nagar, Bandra East, Mumbai-400 051 ...... Appellant Vs. Ito Ward 23(2)(3) Matru Mandir, Tardeo Raod, Mumbai-400 007 Pan – Aabam0722B ..... Respondent

For Appellant: Shri Dharan Gandhi, Ld. ARFor Respondent: Smt. Mahita Nair, CIT-DR

Section 143(2)Section 143(3)Section 250Section 80PSection 80P(2)(d)

from different channels, that same was not permissible under byelaws of the society, that it had transferred a sum of Rs.2.97 Crores from the corpus fund to the P&L account, that such investment in banks would not qualify for deduction u/s. 80P of the Act. Finally, he denied

ACIT Special Range-1, New Delhi vs. Agricultural Insurance Company of India Ltd., New Delhi

In the result, the appeal of the Revenue is dismissed

ITA 891/DEL/2019[2015-16]Status: DisposedITAT Delhi30 Jun 2023AY 2015-16

Bench: Sh. Saktijit Deydr. B. R. R. Kumar

For Appellant: Sh. Akash Singhal, CA &For Respondent: Sh. Kanv Bali, Sr. DR

Section 14A

Delhi dated 22.11.2018. 2. At the outset, it was brought to our notice that the identical issue of disallowance u/s 14A and interest on corpus fund has been a subject matter of adjudication in assessee’s own case for A.Y. 2012-13 by the Tribunal vide order dated

ITO (E)-2(3), Mumbai vs. Sangit Kala Kendra, Mumbai

In the result, appeal filed by the Revenue/Department stands dismissed

ITA 773/MUM/2023[2015-16]Status: DisposedITAT Mumbai20 Jun 2023AY 2015-16

Bench: Shri Narender Kumar Choudhryito-2(3), Versus Sangit Kala Kendra, Room No. 617, 6Th Floor, 1St Floor, 159,Industry Mtnl Building,Cumballa Hill House,Padmabhushan Mumbai-400026. H.T. Parekh Marg, Churchgate Reclamation, Mumbai-400020. Pan: Aaats1345J Appellant Respondent

For Appellant: Sh. Sunil HirawatFor Respondent: Ms. Mini Vinod, DR

Section 11(1)(d)Section 250

Branch in the case of Indian Society of officers, Anaesthesiologists v/s ITO (ITA No. 507/Mds/2014) on the issue whether the Life membership fees is corpus funds or not. I have examined all the details filed by the appellant before the AO and the facts of the case. I have seen ... Honorary Secretary of the Assessee Society, to Shri Lalit Daga, one of the General Members, wherein the following details have been mentioned as Corpus Fund. * Corpus Fund (Entrance Fees) Rs.75,000.00 * Half yearly subscription Rs. 25,00.00 * Service Tax @ 12.36% Rs. 9,579.00 * Identity Card Charges Rs. 200.00 Total

Lok Bharti Mandal, Surat vs. The Income Tax Officer (Exemption) Ward, Surat

In the result, appeal filed by the assessee is partly allowed in above terms

ITA 212/SRT/2023[2008-09]Status: DisposedITAT Surat16 Jun 2023AY 2008-09

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita No.212/Srt/2023 "नधा"रण वष"/Assessment Year: (2008-09) (Physical Hearing) Lok Bharati Mandal, Vs. The Ito, Bharatia Vidhya Sankul, Opp. Terapanthi (Exemption) Ward, Bhavan, City Light Ropad, Surat. Surat – 395007. (Assessee) (Respondent) "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaatl2524Q Assessee By Shri Hiren Vepari, Ca Respondent By Shri Vinod Kumar, Sr. Dr 04/05/2023 Date Of Hearing Date Of Pronouncement 16/06/2023

Section 11(1)(d)Section 143(3)

Fund 30,00,000 TOTAL 51,38,851 On this issue the A.O has gone further and observed that the earmarked fund claimed as corpus fund only involve various receipts/donations received by the assessee from donors on account of New Building fund of Rs.2.38 lakhs, Room donation ... further examined and held that the assessee trust deed nowhere mentions any such earmarked funds to be treated as corpus fund / part of corpus fund of the trust. Accordingly, when the corpus fund is not so specified precisely to say what constitutes a corpus fund of trust, the same cannot

Kakatiya Sangham, Tanuku vs. Incpme Tax Officer, Ward-1, Tanuku

In the result, appeal filed by the assessee is allowed

ITA 19/VIZ/2023[2012-13]Status: DisposedITAT Visakhapatnam15 Jun 2023AY 2012-13

Bench: Shri Duvvuru Rl Reddy, Hon’Bleआयकर अपील सं./I.T.A.No.19/Viz/2023 (ननधधारण वर्ा / Assessment Year : 2012-13) Kakatiya Sangham Vs. Income Tax Officer D.No.4-348 Ward-1 Bypass Road (Chivatam) Tanuku Tanuku, West Godavari Dist. [Pan : Aaatk7209H] अपीलधथी की ओर से/ Appellant By : Shri G.V.N.Hari, Ar प्रत्यधथी की ओर से / Respondent By : Shri O.N.Hari Prasada Rao, Dr सुनवधई की तधरीख / Date Of Hearing : 19.04.2023 घोर्णध की तधरीख/Date Of Pronouncement : 15.06.2023 आदेश /O R D E R Per Shri Duvvuru Rl Reddy: Condonation Of Delay : This Appeal Is Filed By The Assessee Against The Order Of Commissioner Of Income Tax (Appeals) [Cit(A)], National Faceless Appeal Centre (Nfac), Delhi In Din & Order No.Itba/Nfac/S/250/2022-23/1043166326(1) Dated 25.05.2022 For The Assessment Year (A.Y.) 2012-13, Arising Out Of The Order Passed U/S 143(3) Of The Income Tax Act, 1961 (In Short ‘Act’) Dated 23.09.2014 With The Delay Of 183 Days. The Assessee Filed Petition For Condonation Of Delay, Submitting That The Order Of The Ld.Cit(A), Nfac, Delhi Was Passed

For Appellant: Shri G.V.N.Hari, ARFor Respondent: Shri O.N.Hari Prasada Rao, DR

Section 12ASection 143(3)Section 2(15)

income, declaring Nil income, against which, the AO completed the assessment on a total income of Rs.22,81,028/- by bringing to charge the corpus fund donations of Rs.24,55,696/- u/s 2(15) of the Act. The AO noticed that the assessee is in receipt of marriage hall maintenance ... cannot be regarded as income u/s 2(24)(iia) of the Act and the provisions of section 2(15) do not apply to the corpus fund donations of a charitable institution. The assessee filed paper book and furnished the detailed list of corpus donations for construction of a mini hall

Ramnath Goenka Memorial Foundation, Mumbai vs. ITO (Exemption) 2(2), Mumbai

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

ITA 1004/MUM/2023[2014-2015]Status: DisposedITAT Mumbai08 Jun 2023AY 2014-2015

Bench: Shri Pavan Kumar Gadaleramnath Goenka Ito (Exemp)-2(2), Memorial Foundation, Room No. 601, 6Th बनाम/ 7Th Floor, Mafatlal Floor, Mtnl Bldg, Vs. Centre, Ramnath Dadar Road, Goenka Marg, Cumballa Hill, Nariman Point, Mumbai-400026 Mumbai – 400021. "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aabtr9441D (""थ" / Respondent) (अपीलाथ" /Appellant)

For Appellant: Mr. S.Venkatraman.ARFor Respondent: Ms. Kavita Kaushik.DR

Section 11Section 11(1)Section 11(1)(d)Section 12ASection 143(2)Section 143(3)Section 250

extent of available income is deductible from the current income. ➤ Any excess expenditure over income is either out of accumulated income or out of corpus fund received by the trust. Accumulated income cannot be further subjected to deduction from the income since deduction in respect of accumulation has been claimed

Iclei South Asia Group Gratuity Trust, New Delhi vs. CIT(E), New Delhi

In the result, the appeal of the assessee is allowed

ITA 762/DEL/2021[2020-21]Status: DisposedITAT Delhi01 Jun 2023AY 2020-21

Bench: Shri C.M. Garg & Shri M. Balaganeshassessment Year: 2018-19 Assessment Year 2021-22 Icrw Group Gratuity Trust, Vs Cit (Exemptions), C-59, Ground Floor, Delhi. South Extension Part Ii, New Delhi 110 049 Pan: Aabti3510L Assessment Year: 2020-21 Iclei South Asia Group Gratuity Trust, Vs Cit (Exemptions), C-3, Lower Ground Floor, Delhi Green Park Extension, New Delhi – 110 016. Pan: Aabti7567H (Appellant) (Respondent) Assessee By : Shri Anand Chaudhuri, Advocate Revenue By : Sh. Mohd. Gayasuddin Ansari,Cit,Dr Date Of Hearing : 17.05.2023 Date Of Pronouncement : 01.06.2023

For Appellant: Shri Anand Chaudhuri, AdvocateFor Respondent: Sh. Mohd. Gayasuddin Ansari,CIT,DR

Section 12ASection 25

normal Indian accounting standards. This was the reason that it was shown in balance sheet instead of instead of income and expenditure account, being corpus fund in nature. 6. Your honour has presumed that a public charitable trust can not be an employer, This presumption is basically wrong because

Icrw Group Gratuity Trust, New Delhi vs. CIT(E), New Delhi

In the result, the appeal of the assessee is allowed

ITA 761/DEL/2021[2021-22]Status: DisposedITAT Delhi01 Jun 2023AY 2021-22

For Appellant: Shri Anand Chaudhuri, AdvocateFor Respondent: Sh. Mohd. Gayasuddin Ansari,CIT,DR

Section 12ASection 25

ITO (E), Ward- 2(3), New Delhi vs. The Managing Committee of Shivala Apa Gangadhar, Delhi

In the result appeal of the Revenue is dismissed and the petition under Rule 27 of the ITAT Rules by the assessee is allowed for statistical purposes

ITA 226/DEL/2018[2014-15]Status: DisposedITAT Delhi30 May 2023AY 2014-15

Bench: Shri Shamim Yahya & Shri Challa Nagendra Prasadआ.अ.सं .I.T.A No. 226/Del/2018 िनधा"रण वष"/Assessment Year: 2014-15 Income Tax Officer (E) The Managing बनाम Committee Of Shivala Vs. Ward : 2 (3) Apa Gangadhar, Near Red Fort, New Delhi. Chandni Chowk, Delhi – 110 006. Pan No. Aaatt7829A अपीलाथ"/ Appellant ""थ"/ Respondent

For Appellant: Shri V. Raj Kumar, Adv

Section 11(1)(d)

engaged in servicing the Temple of Lord Shiva and Devi Parvathi located in Chandni Chowk, Delhi. The assessee has credited Rs.74,47,590/- in corpus fund in temple being the amount of offerings to God, which are exempt from tax. The assessee also contended that a sum of Rs.87 ... corpus. It has also been submitted that it is not necessary that a donor should give in writing that the subscription is towards the corpus fund and that the receipt is issued after receiving a donation indicating that ITA. No. 226/Del/2018 the donation would be used for the building fund

Peace Fellowship Charitable Trust, Kakinada vs. Income Tax Officer(Exemptions Ward), Rajahmundry

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

ITA 112/VIZ/2023[2019-20]Status: DisposedITAT Visakhapatnam30 May 2023AY 2019-20

Bench: Shri Duvvuru Rl Reddy, Hon’Bleआयकर अपील सं./ I.T.A. No.112/Viz/2023 ("नधा"रण वष" / Assessment Year :2019-20) Peace Fellowship Charitable Vs. Income Tax Officer Trust, Kakinada. (Exemption Ward), Pan: Aadtp 4911 A Rajahmundry. (अपीलाथ"/ Appellant) (""यथ"/ Respondent) अपीलाथ" क" ओर से/ Appellant By : Smt. A. Aruna, Ar ""याथ" क" ओर से / Respondent By : Sri Sankar Pandi, Sr. Ar

For Appellant: Smt. A. Aruna, ARFor Respondent: Sri Sankar Pandi, Sr. AR

Section 11Section 12ASection 142(1)Section 143(1)Section 143(3)

justified in sustaining the addition of Rs. 2,45,072/- made by the Assessing Officer towards opening balance of corpus fund. 6. The Ld. CIT(A) is not justified in sustaining the addition of Rs. 3,23,437 made by the Assessing Officer towards disallowance of 75% of the expenses