“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

DCIT, Circle-1(1), New Delhi vs. Agriculture Insurance Company of India Ltd, Delhi

In the result, appeals are dismissed

ITA 2563/DEL/2022[2017-18]Status: DisposedITAT Delhi29 May 2023AY 2017-18

Bench: Shri G.S. Pannu & Shri Saktijit Dey

For Appellant: Sh. Akash Singhal, C.AFor Respondent: Ms. Sapna Bhatia, CIT-DR

Section 14A

case and in law, the Ld. CIT(A) was justified in deleting the addition of Rs.5,65,41,062/- on account of corpus fund without routing the income through the profit and loss account. The Ld. CIT(A) was not justified in not treating the same as diversion of income ... account of disallowance u/s. 14A r.w.r. 8D of the Income-tax Rules.” 3. First issue relates to deletion of addition made on account of corpus fund without routing the income through profit and loss account. 4. Briefly, the facts are, the assessee is a public limited company and has been

DCIT, Circle-1(1), New Delhi vs. Agriculture Insurance Company of India Ltd, Delhi

In the result, appeals are dismissed

ITA 2562/DEL/2022[2016-17]Status: DisposedITAT Delhi29 May 2023AY 2016-17

Bench: Shri G.S. Pannu & Shri Saktijit Dey

For Appellant: Sh. Akash Singhal, C.AFor Respondent: Ms. Sapna Bhatia, CIT-DR

Section 14A

Ayyappa Seva Samgham Bombay Trust, Mumbai vs. CIT (A)-53, Mumbai

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

ITA 135/MUM/2023[2017-18]Status: DisposedITAT Mumbai15 May 2023AY 2017-18

Bench: Shri Kuldip Singh & Shri Gagan Goyalayyappa Seva Samgham Bombay-Trust Plot No.185, Shree Ayyappa Temple Bangur Nagar, Goregaon (E) Mumbai-400 104 Pan: Aaata0312K ...... Appellant Vs. Cit (A), 53 634, Aayakar Bhavan, Mumbai-400 020 ..... Respondent

For Appellant: Shri S. C. TiwariFor Respondent: Smt. Shailja Rai CIT-DR

Section 11Section 115BSection 12ASection 133ASection 143(3)Section 263Section 69A

concerned, we set aside the matter back to AO for verification with a direction that if interest so claimed by the assessee pertains to corpus fund, then the same has to be allowed as accretion to corpus fund, otherwise it will be deemed to be the income of the assessee

The Guru Govind Singh Educational Society, Moga vs. The Income Tax Officer, Moga

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

ITA 344/ASR/2016[2010-11]Status: DisposedITAT Amritsar15 May 2023AY 2010-11

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

Section 10Section 11Section 11(1)Section 12ASection 143(3)Section 250

That the appellant had legitimate source of donation of Rs. 97,42,782/- received as corpus fund of the society and also submitted detailed list of all the donors along with their names and addresses as required by the assessing authority and all the donors had also admitted before ... assessing authority during the assessment proceeding and Ld CIT(A) erred in confirming in the same. 4. That the amount of donations received as corpus fund were duly utilized for construction of school building as per the objects of the society and confirmation of addition

Narayan Devarajan Iyengar, Mumbai vs. Income Tax Officer, International Tax, Ward 2(2)(1), Mumbai

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

ITA 106/MUM/2023[2015-16]Status: DisposedITAT Mumbai10 May 2023AY 2015-16

Bench: Shri G.S. Pannu & Shri Sandeep Singh Karhail

For Appellant: Dr. K. Shivaram a/wFor Respondent: Shri Dilip K. Shah

Section 142(1)Section 143(2)Section 144CSection 144C(13)Section 144C(5)Section 147Section 148

dismissed. 4. The issue arising in grounds no.2 and 3, raised in assessee‟s appeal, is pertaining to the addition on account of corpus fund and rent for alternate accommodation received by the assessee from the Developer/Builder. 5. The brief facts of the case pertaining to this issue ... Iyengar ITA no.106/Mum./2023 S.A. no.29/Mum./2023 Rustomjee Constructions Pvt. Ltd. In response thereto, the assessee submitted that amount of Rs.64 lakhs is a corpus fund and therefore, it is a capital receipt and is not taxable. The Assessing Officer (“AO”) vide draft assessment order dated 29/01/2022 passed under section

Shri Maheshwari Jankaiyan Trust, Indore vs. The CIT Exemption, Bhopal

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

ITA 123/IND/2022[2017-18]Status: DisposedITAT Indore17 Apr 2023AY 2017-18

Bench: Shri T.R. Senthil Kumar (Judicial Member), Shri B.M. Biyani (Accountant Member)

Section 11(1)(a)Section 12ASection 2(15)Section 263Section 80G

immovable property. (f) The balance Sheet show different figures in capital account as on 31.03.2017 vis-à-vis 31.03.2016 by way of introduction of corpus fund amounting to Rs 99,85,000/-, which coincides with demonetization period, and which was one of the issues for selection of the case

Guru Gobind Singh Educational Society, Moga vs. Income Tax Officer Exemptions, Jalandhar

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

ITA 576/ASR/2018[2011-12]Status: DisposedITAT Amritsar10 Apr 2023AY 2011-12

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

Section 10Section 11Section 11(1)(d)Section 12ASection 148Section 250

Confirmation Of Addition By Ld CIT (A) Is Bad In Law. 3. That The Appellant Had Legitimate Source Of Donation Of Rs.388430Q/-Received As Corpus Fund Of The Society And Also Submitted Detailed List Of All The Donors Along With Their Names And Addresses As Required By Assessing Authority ... Assessing Authority During The Assessment Proceeding And Ld CIT (A) Erred In Confirming In The Same. 4. That The Amount Of Donations Received As Corpus Fund Were Duly Utilized For Construction Of School Building As Per The Objects Of The Society And Confirmation Of Addition

Late Shantaben Chandrashankar Vyas Charitable Trust, Rajkot vs. The Deputy Commissioner of Income Tax, (CPC), Bangalore

In the result, the appeal of the assesse is hereby dismissed

ITA 25/RJT/2022[2018-19]Status: DisposedITAT Rajkot24 Mar 2023AY 2018-19

Bench: Shri Waseem Ahmed & Shri Siddhartha Nautiyalआयकर अपील सं./Ita No.25/Rjt/2022 िनधा"रण िनधा"रण वष" िनधा"रण िनधा"रण वष" वष"/Asstt. Years: 2018-2019 वष"

For Appellant: Shri J.R. Mankodi, A.RFor Respondent: Shri Shramdeep Sinha, Sr. D.R

Section 11Section 12ASection 12A(1)Section 12A(2)Section 143(1)

year under consideration i.e. A.Y. 2018-19 dated 13-09-2018 claimed benefit of section 11 and 12 of the Act on account of corpus fund and voluntary contribution applied towards the objects. The CPC in the intimation generated under section 143(1) of the Act dated 30th September

Shri Rajkot Vishashrimali Jain Samaj, Rajkot vs. The ITO, Exemption Ward-1, Rajkot

In the result, appeal of the assessee is allowed

ITA 256/RJT/2022[2020-21]Status: DisposedITAT Rajkot13 Mar 2023AY 2020-21

Bench: Shri Waseem Ahmed (Accountant Member), Shri Siddhartha Nautiyal (Judicial Member)

For Appellant: Shri G.R. Sanghavi, A.RFor Respondent: Shri B.D. Gupta, Sr. D.R

Section 11Section 119(2)(b)Section 12ASection 139Section 143Section 143(1)Section 250Section 288

appellant e-filed its return of income on 10/02/2021 declaring therein income and expenditures as under: Particulars Amount (Rs.) Voluntary contribution other than corpus fund 12,000 Income u/s 11/12 13,93,398 Gross Income 14,05,398 Less: Total Deductions / Exemptions claimed u/s 11 (12,72,788) I.T.A

Bhag Kaur and Harnam Singh Zoria, Dasuya vs. Commissioner of Income Tax ( Exemptions), Chandigarh

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

ITA 16/ASR/2021[2020-21]Status: DisposedITAT Amritsar01 Mar 2023AY 2020-21

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

Section 10Section 11Section 11(1)(d)Section 12A

registration was applied under provision of 12AA before the ld.CIT(E). The ld. CIT(E) rejected the application on the ground that for corpus funds I.T.A. No.16/Asr/2021 3 Assessment Year: 2020-21 received before the exemption and there is absence of FCRA Certificate which is clear violation of FCRA norms ... related to foreign donation. There is allegation against the assessee for amount of Rs. 57,74,845/- as Corpus Fund in its Balance Sheet for F.Y. 2018-19 which was supposed to take as income in the FY 2018-19 as per the ld. CIT(E). The assessee filed requisite

Mesers Peer Panchal Educational and Welfare Trust, Jammu and Kashmir vs. Commissioner of Income Tax(Exemptions), Chandigarh

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

ITA 598/ASR/2018[2018-19]Status: DisposedITAT Amritsar28 Feb 2023AY 2018-19

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

Section 10Section 12A

Please provide the Source of financing of fixed assets of nearly a crore in F. Y. 2015-16. (ii) Please provide details/evidence of corpus fund addition during F.Y. 2016- 17 to the tune of Rs. 20.90 lakhs. (iii) Please provide details/evidence including purpose behind sundry creditors existing ... Further, on perusal of the Balance sheet as on 31.03.2017 it was observed that the applicant trust is showing Rs. 20.90 lakhs/- as corpus fund. To verify the claim, the applicant trust was asked to submit the documentary proof vide e-mail dated 21.09.2018. In response to the same

Pushp Niketan School Samiti, Biijnore vs. ITO, Dhampur

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

ITA 1130/DEL/2019[2015-16]Status: DisposedITAT Delhi30 Jan 2023AY 2015-16

Bench: Shri Kul Bharat[Assessment Year : 2015-16] Pushp Niketan School Samiti, Vs Ito, Sugar Mill, Campus Dhampur, Dhampur, Bijnor, Bijnor, Uttar Pradesh-246761. Uttar Pradesh, Pan-Aabtp8074C Appellant Respondent Appellant By None Respondent By Shri Om Parkash, Sr.Dr Date Of Hearing 18.01.2023 Date Of Pronouncement 30.01.2023 Order Per Kul Bharat, Jm : The Present Appeal Filed By The Assessee For The Assessment Year 2015- 16 Is Directed Against The Order Of Ld. Cit(A)-11, New Delhi Dated 20.06.2019. The Assessee Has Raised Following Ground Of Appeal:- 1. “Learned Cit(Appeals) Erred In Law & On Facts In Confirming The Addition Of Interest & Other Income Of Rs.2,45,757/- By Not Treating The Same As Income Of Educational Institute.” 2. At The Time Of Hearing, No One Attended The Proceedings On Behalf Of The Assessee. It Is Seen From The Records That No One Has Been Attending The Proceedings On Behalf Of The Assessee Since 05.01.2021. Therefore, The Appeal Is Taken Up For Hearing In The Absence Of The Assessee & Is Being Decided On The Basis Of The Material Placed On Record.

Section 10Section 143(3)

thereby, he made addition of Rs.4,99,601/- in respect of disallowance of expenses being non-vouched. Further, he made addition in respect of Corpus fund of Rs.1,25,366/- and addition in respect of interest income amounting to Rs.2,45,757/-. 4. Aggrieved against this, the assessee preferred appeal

ITO Exmp., Agra vs. Shri Girraj Sewak Samiti, Mathura

ITA 1553/DEL/2019[2010-11]Status: HeardITAT Delhi16 Jan 2023AY 2010-11

Bench: Sh. N. K. Billaiya & Sh. Anubhav Sharmaassessment Year: 2010-11 Ito Exmp Sh. Girraj Sewak Samiti Agra Vs Danghati Goverdhan, Mathura Pan No.Aaets4783Q (Appellant) (Respondent)

facts of the case are that during the course of the scrutiny proceedings the AO noticed that the amount of Rs.69398863/- appearing as corpus fund is nothing but voluntary donations made by pilgrims whose names are unknown and they have not donated this amount for any specific purpose

Shri Ram Education & Graminvikas Charitable Trust, Valsad vs. Income Tax Officer ( Exemption Ward), Surat

In the result, this appeal of the assessee is dismissed

ITA 213/SRT/2018[2013-14]Status: DisposedITAT Surat16 Jan 2023AY 2013-14

Bench: Shri Pawan Singh & Dr. Arjun Lal Sainishri Ram Education & I.T.O., (Exemption Ward) Graminvikas Charitable Trust, Aayakar Bhavan, Vs. Jauagauri Park, Hathikhana, Majura Gate, Dharampur, Surat. Valsad-396050. Pan No. Aalts 324 F Appellant/ Assessee Respondent/ Revenue

Section 10(23)(C)Section 11aSection 12ASection 133(6)Section 142(1)Section 254(1)

case as well in law, both the lower authorities have grievously failed to appreciate the fact that there is no contributions towards the corpus fund received during the relevant year and hence, the addition of Rs. 8,4,700/- made/confirmed on account of alleged fresh contributions towards the corpus fund ... assessee in part compliance furnished the balance sheet of A.Y. 2012-13 and informed that there was no addition to the “trust or corpus fund” during the A.Y. 2013- 134 as the closing balance of such funds as on 31/3/2012 was Rs. 13,34,700/-. The Assessing Officer recorded that

Akshay Educational & Social Welfare Charitable Trust, Bodhgaya vs. DCIT, Circle-3, Gaya

In the result, the appeal of the assessee is hereby dismissed

ITA 3/PAT/2017[2011-12]Status: DisposedITAT Patna11 Jan 2023AY 2011-12

Bench: Shri Sanjay Garg & Shri Rajesh Kumari.T.A. No.03/Pat/2017 Assessment Year: 2011-12 Akshay Educational & Social Welfare Charitable Trust............……….……Appellant Amawa (Thakar), Bodhgaya-824234. [Pan:Aacta5613R] Vs. Dcit, Circle-3, Gaya….....………............…............……........……...…..…..Respondent Appearances By: Shri A.K. Rastogi, Sr. Adv. & Shri Rakesh Kumar, Advocate, Appeared On Behalf Of The Appellant. Smt. Rinku Singh, Cit-Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : November 21, 2022 Date Of Pronouncing The Order : January 11, 2023 आदेश / Order संजय गग", "या"यक सद"य "वारा / Per Sanjay Garg: The Present Appeal Has Been Preferred By The Assessee Against The Order Dated 26.08.2016 Of The Commissioner Of Income Tax (Appeals)-1, Patna [Hereinafter Referred To As ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’). The Assessee In This Appeal Has Taken The Following Grounds Of Appeal:

Section 11Section 12ASection 250

Chairman can use the fund for the development of trust activities. The assessee trust, therefore, claimed that the said donation was towards the corpus fund of the trust with a specific direction to be used for infrastructural development and, therefore, the same was a capital receipt, not taxable even ... However, the Assessing Officer did not agree with the above contention of the assessee and held that the exemption for donation received towards corpus fund was available to a trust only if the same was registered u/s 12A of the Act. 5. In appeal, the ld. CIT(A) confirmed

M/S. Srinivas Institute of Medical Science and Research Centre, Mangalroe vs. The Principal Commissioner of Income Tax (Central), Bengaluru

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

ITA 533/BANG/2022[N/A]Status: DisposedITAT Bangalore30 Dec 2022

Bench: Shri N.V. Vasudevan & Shri Chandra Poojariassessment Year: N.A.

For Appellant: Shri V. Srinivasan, A.RFor Respondent: Dr. G. Manoj Kumar, D.R

Section 10Section 11Section 12ASection 269S

fact, furnished a list running into staggering 29 pages showing the names of the students in standard-wise and also the contributions towards 'corpus fund'. Copies of ledger accounts of different corpus funds produced by the assessee for verification exhibited that the amounts received had been credited to each fund ... account of each receipt from the parents/students. Apart from such contributions towards 'corpus funds', it was noticed that the students had also paid towards tuition fees every year. It was held by tribunal that had the contribution collected been towards education to be imparted by the school as alleged

Skyline Millars Limited, Mumbai vs. Pr. Comm of Income Tax, Mumabi 6, Mumbai

In the result appeal of the assessee is fully allowed

ITA 776/MUM/2022[2017-18]Status: DisposedITAT Mumbai16 Dec 2022AY 2017-18

Bench: Shri Kuldip Singh & Shri Gagan Goyalskyline Millars Ltd. 24 Po Box No. 9208, Kurla Kirol Road, Ghatkopar (W), Mumbai-400086. Pan: Aaact2755J ...... Appellant Vs. Pr. Commissioner Of Income Tax-6, Room No. 501, Aayakar Bhavan, M.K. Road, Mumbai-400020. ..... Respondent Appellant By : Sh. Dalpat Shah, Ca Respondent By : Sh. Rakesh Garg, Cit-Dr Date Of Hearing : 22/09/2022 Date Of Pronouncement : 16/12/2022 Order Per Gagan Goyal, A.M: This Appeal By The Assessee Is Directed Against The Order Of Pr. Commissioner Of Income Tax-6, Mumbai Dated 31.03.2022 Under Section 263 Of The Income Tax Act, 1961 (For Short ‘The Act’) For A.Y. 2017-18. The Assessee Has Raised The Following Grounds Of Appeal: “1. Order U/Sec. 263 Of The Income Tax Act Is Bad-In-Law.

For Appellant: Sh. Dalpat Shah, CAFor Respondent: Sh. Rakesh Garg, CIT-DR

Section 142(1)Section 143(3)Section 263

have stated that out of above interest received from Axis Bank Ltd "Rs 3,68,760/- is placed out of corpus funds of societies Maintenance Account of Erbent and Tadmor Building constructed by the assessee Company at Vidyavihar (West). Since the fixed Deposit represents funds of the society, the interest

Vighnaharata Trust, Mumbai vs. CIT (Exemption), Mumbai

Accordingly, the appeal filed by the assessee is allowed

ITA 1284/MUM/2021[2011-12]Status: DisposedITAT Mumbai15 Dec 2022AY 2011-12

Bench: Shri Prashant Maharishi, Am & Ms Kavitha Rajagopal, Jm Vighnaharata Trust Cit (Exemption) 1605/06 Hurrah, City Of Joy, Room No-617, 6Th Floor, Near Railway Station, Lbs Piramal Chamber, Lalbaug, Vs. Marg, Mulund West, Mumbai- Parel, Mumbai- 400 012 400 080 (Appellant) (Respondent) Pan No. Aaatv8040K Assessee By : Shri. Rajeev Khandelwal Revenue By : Shri. Achal Sharma Cit Dr Date Of Hearing: 02.11.2022 Date Of Pronouncement: 15.12.2022

For Appellant: Shri. Rajeev KhandelwalFor Respondent: Shri. Achal Sharma CIT DR

Section 10Section 11Section 115BSection 12ASection 143(3)Section 148Section 263Section 292B

above, the donation of the assessee is far from convincing and is a cooked- up story, and, therefore, cannot be accepted. ( c ) The total corpus fund being building fund shown by the assessee to the extent of ₹ 55,204,903/– in the balance sheet. This donation

Parab Maratha Samaj, Mumbai vs. National Faceless Assessment Centre, Delhi

In the result, the appeal filed by the assessee stands partly allowed

ITA 1821/MUM/2022[2019-20]Status: DisposedITAT Mumbai30 Nov 2022AY 2019-20

Bench: Shri Amit Shukla, Jm आयकरअपीलसं./ I.T.A. No. 1821/Mum/2022 (निर्धारणवर्ा / Assessment Year: 2019-20) Parab Maratha Samaj, Nfac, Delhi बिधम/ 10, 5Th Floor Mahohar Bldg, Priti Kanha, Chitable Path, Vs. Dadar(W), Mumbai-400 028 स्थायीलेखासं./जीआइआरसं./ Pan No. Aaatp4197P (अपीलाथी/Appellant) (प्रत्यथी / Respondent) : अपीलाथीकीओरसे/ Appellant By : Shri Dinesh Shah, Ld. Ar प्रत्यथीकीओरसे/Respondent By : Ms. Neeta Jeph, Ld. Dr सुनवाईकीतारीख/ : 01.09.2022 Date Of Hearing घोषणाकीतारीख / : 30.11.2022 Date Of Pronouncement आदेश / O R D E R Per Amit Shukla: The Aforesaid Appeal Has Been Filed By The Assessee Against The Impugned Order Dated 09.05.2022, Passed By National Faceless Appeal Centre (Nfac), Delhi For The Quantum Of Assessment Passed U/S 143(3) For Ay 2019-20. The Assessee Has Raised The Following Grounds Of Appeal:-

For Appellant: Shri Dinesh Shah, Ld. ARFor Respondent: Ms. Neeta Jeph, Ld. DR

Section 11Section 12ASection 143(3)

made. (3rd proviso to S.12A) 3. The appellant had earned interest income of Rs 1,48,585 which pertained to FD in connection with corpus fund and hence the same cannot be added to the income. 4. The appellant has spent amount aggregating ... Total Receipts as per I & E Rs. 1,73,709 5 I.T.A. No. 1821/Mum/2022 Parab Maratha Samaj b) Interest income credited to three corpus funds- - Education Fund Rs 52,698 - Health Fund Rs 53,459 - General Fund Rs 42,428 Total Rs 1,48,585 c) Total Income

Lions Club of Malad Borivali Charity Trust, Mumbai vs. CIT Exemptions, Mumbai

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

ITA 1458/MUM/2022[2017-18]Status: DisposedITAT Mumbai27 Sept 2022AY 2017-18

Bench: Shri Kuldip Singh () & Shri Om Prakash Kant () Assessment Year: 2017-18 Lions Club Of Malad Borivali Cit Exemptions, Charity Trust, 601,6Th Floor, Cumballa Hills, Pd Lions College, Sv Road, Vs. Mumbai-400026. Sunder Nagar, Malad West, Mumbai-400064. Pan No. Aaatl 1407 C Appellant Respondent Assessee By : Mr. Shankarlal Jain, Ar Revenue By : Ms. Shailja Rai, Cit-Dr Date Of Hearing : 24/08/2022 Date Of Pronouncement : 27/09/2022

For Appellant: Mr. Shankarlal Jain, ARFor Respondent: Ms. Shailja Rai, CIT-DR

that the receipt of development welfare fund are admittedly we find that the receipt of development welfare fund are admittedly not part of the corpus fund and therefore, under the provisions of not part of the corpus fund and therefore, under the provisions of not part of the corpus fund