“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

Haryana Building and Other Construction Workers Welfare Board, Panchkula vs. CIT(Exemption), Chandigarh

In the result, this appeal of the Assessee stands dismissed

ITA 63/CHANDI/2021[2015-16]Status: DisposedITAT Chandigarh10 Dec 2025AY 2015-16

Bench: Shri Laliet Kumar & Shri Krinwant Sahay

For Appellant: Sh. Nikhil Goyal, AdvocateFor Respondent: Sh. Manav Bansal, CIT DR

Section 263

funds. 4. 8. Thus, the cess collected does not vest in the Board as its income or revenue receipt, but rather as an earmarked corpus fund, held in fiduciary capacity for the benefit of registered workers. It is a settled principle of law that receipts which are statutorily earmarked ... utility purposes are not liable to be treated as having earned taxable income, as the amounts so collected partake the nature of trust or corpus funds. 4. 9. Accordingly, the cess collections of the appellant-Board are basically linked to its statutory obligation and welfare objects, and therefore, must

Sree Maruthi Cooperative Housing Society, Bengaluru vs. Income Tax Officer, Ward-7(2)(3), Bengaluru

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

ITA 1895/BANG/2024[2016-17]Status: DisposedITAT Bangalore09 Dec 2025AY 2016-17

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

For Appellant: Shri Ravishankar, AdvocateFor Respondent: Shri Subramanian .S, JCIT-DR

Section 142(1)Section 143(1)Section 143(2)Section 234BSection 250Section 801Section 80P(2)(a)Section 80P(4)Section 8o

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

ACIT, Exemptions, Circle-1, Ahmedabad vs. Vyakti Vikas Kendra India, Ahmedabad

In the result, the appeal of the Revenue is dismissed

ITA 1656/AHD/2025[2016-17]Status: DisposedITAT Ahmedabad02 Dec 2025AY 2016-17

Bench: Ms. Suchitra Kamble & Shri Narendra Prasad Sinhaassessment Year: 2016-17

Section 10(23)(iiiad)Section 11Section 11(1)(a)Section 11(1)(d)Section 11(2)Section 143(3)Section 2(15)

denied by the Assessing Officer. Further, the Assessing Officer had also held that the assessee was not entitled for deduction of corpus fund donation u/s 11 of the Act as it was not entitled to claim any benefit under sections 11, 12 & 13 of the Act. For the same reason

Haryana Saraswati Heritage Development Board, Panchkula, Haryana vs. DCIT/ACIT(E)(Circle-2) Chandigarh, Chandigarh

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

ITA 962/CHANDI/2025[2017-18]Status: DisposedITAT Chandigarh28 Nov 2025AY 2017-18

Section 11Section 12ASection 142(1)Section 143(2)Section 164(3)Section 270A

preferred in appeal before the Tribunal. 6. During the course of hearing the Ld. Counsel for the Assessee argued that the assessee has received corpus fund /grant in aid from the Government of Haryana under section 11(1)(d) therefore it should not considered as income of the assessee, accordingly ... previous year" It is further submitted that the Receipts do not include the amount of Voluntary Contribution received in the form of Corpus Fund in accordance with section 11(1)(d) of the Act. The amount of Corpus Fund is shown in "Column Ai of Schedule VC" in the return

Shri Parshvanath Digambar Jain Dharmik and Samajik Sanstha, Ram Gali, Neemuch Cant vs. Income Tax Officer, Aaykar Bhawan Indore

Appeal is allowed for statistical purpose

ITA 353/IND/2025[2017-2018]Status: DisposedITAT Indore27 Nov 2025AY 2017-2018

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

Section 124ASection 144Section 69A

voluntary offerings, applied entirely to religious and charitable activities, 1. The Trustees resolved to renovate and develop the temple prémises and created a dedicated Corpus Fund, To mobilize resources, customary Jain Practices were adopted: (i) placement of a ’ donation box; (ii) collection of ‘Boli’ amounts for religious activities ... contributions received for a specific Purposes cannot be regarded as income ws 2(24)(iia) of the Act since they were capital receipts being corpus fund and tied up grants for specific purposes. In our considered view keeping in view ’ our detailed discussions above and the case laws cited before

Thakur Roshan Singh, Bareilly vs. ITO (Exemption) Ward, Bareilly

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

ITA 530/LKW/2024[2018-19]Status: DisposedITAT Lucknow24 Nov 2025AY 2018-19

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudharya.Y. 2018-19 Thakur Roshan Singh, Smirti Sansthan, Vs. Income Tax Officer Vill Chathiya Faizu, Shahpur, Baniyan (Exemption), Ward, Bareilly Faridpur, Bareilly Pan: Aabat8692F (Appellant) (Respondent) Assessee By: Ms. Gurneet Kaur, Adv Revenue By: Sh. R.R.N. Shukla, Addl Cit Dr Date Of Hearing: 04.11.2025 Date Of Pronouncement: 24.11.2025 O R D E R Per Nikhil Choudhary, A.M.: This Is An Appeal Filed By The Assessee Against The Orders Of The Ld. Cit(A), Nfac Dated 4.07.2024, Wherein The Ld. Cit(A) Has Dismissed The Appeal Of The Assessee Against The Order Under Section 143(3) Of The Income Tax Act, 1961 Dated 16.04.2021. The Grounds Of Appeal Are As Under: - “1. Because, On The Facts & In The Circumstances Of The Case, The Ld. Commissioner Of Income Tax (Appeals) Has Erred In Fact & In Law In Confirming The Disallowance Made By Assessing Officer Rs. 60,20,000/- As Building Expenditure For Charitable Purposes, Arbitrarily Rejecting The Explanation Furnished By The Assessee. 2. Because, On The Facts & In The Circumstances Of The Case, The Ld. Commissioner Of Income Tax (Appeals) Has Erred In Fact & In Law That Such College Is Being Constructed & Run In The Remote Village Where In Due To Various Exigencies & Not Availability Of The Banking Facilities, Payments Are Made In Cash. 3. Because, On The Facts & In The Circumstances Of The Case, The Ld. Commissioner Of Income Tax (Appeals) Has Erred In Fact & In Law That The Payments Of Construction Had Made Not Being Rejected By The Ld. Ao. However, Due To Ongoing Work It Is A General Practice To Obtain Bills/Settlement Receipts Only On Finalization Of The Work, The Ld. Ao Has Arbitrarily Rejected The Same.

For Appellant: Ms. Gurneet Kaur, AdvFor Respondent: Sh. R.R.N. Shukla, Addl CIT DR

Section 143(3)

noticed that during the year under consideration, the assessee had shown total receipts of Rs. 1,01,75,358/- including donation to corpus fund amounting to Rs. 37,50,860/-. During the year under consideration, the assessee had shown Revenue expenditure of Rs. 44,43,168/-, building construction expenditure

Dudhsagar Research and Dement Association, Mehsana vs. The Dy.CIT, Circle-1, Exemption, Ahmedabad

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

ITA 203/AHD/2025[2017-18]Status: DisposedITAT Ahmedabad17 Nov 2025AY 2017-18

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

For Appellant: Shri S N Divatia, ARFor Respondent: Shri R P Rastogi, CIT-DR

Section 11Section 11(1)(d)Section 13(8)Section 2(15)Section 250

have any choice or say in the matter whatsoever. Merely producing a receipt which states that the amount has been paid towards the corpus fund of the appellant cannot lead us to accept that the contribution qualifies as a ‘Corpus donation’ when notably these receipts do not even state

Dudhsagar Research and Dement Association, Mehsana vs. The Dy.CIT, Cicle-1, Exemption, Ahmedabad

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

ITA 202/AHD/2025[2016-17]Status: DisposedITAT Ahmedabad17 Nov 2025AY 2016-17

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

For Appellant: Shri S N Divatia, ARFor Respondent: Shri R P Rastogi, CIT-DR

Section 11Section 11(1)(d)Section 13(8)Section 2(15)Section 250

Ujjaini Mahakali Devasthanam, Secunderabad vs. ITO., Exemption Ward-1(3), Hyderabad

In the result, all the six appeals of the Assessee are allowed for statistical purposes

ITA 1385/HYD/2025[2016-17]Status: DisposedITAT Hyderabad12 Nov 2025AY 2016-17

Bench: Shri Vijay Pal Rao & Shri Manjunatha Gआ.अपी.सं /Ita Nos.1382 & 1384/Hyd./2025 िनधा"रण वष"/Assessment Years 2015-2016 & 2016-2017

For Appellant: Sri KVSSN Kumar, AdvocateFor Respondent: Dr. Sachin Kumar, Sr. AR

Section 10Section 147Section 15(1)Section 271BSection 6

collections. Therefore, assessing the entire deposit without considering the earlier assessment order dated 30.11.2019 as well as without allowng the deduction of expenses and corpus fund, if any, such addition made by the Assessing Officer is highly arbitrary. Though the assessee challenged the action of the Assessing Officer before

Ujjaini Mahakali Devasthanam, Secunderabad vs. ITO., Exemption Ward-1(3), Hyderabad

In the result, all the six appeals of the Assessee are allowed for statistical purposes

ITA 1384/HYD/2025[20216-17]Status: DisposedITAT Hyderabad12 Nov 2025

Bench: Shri Vijay Pal Rao & Shri Manjunatha Gआ.अपी.सं /Ita Nos.1382 & 1384/Hyd./2025 िनधा"रण वष"/Assessment Years 2015-2016 & 2016-2017

For Appellant: Sri KVSSN Kumar, AdvocateFor Respondent: Dr. Sachin Kumar, Sr. AR

Section 10Section 147Section 15(1)Section 271BSection 6

Ujjaini Mahakali Devasthanam, Secunderabad vs. ITO., Exemption Ward-1(3), Hyderabad

In the result, all the six appeals of the Assessee are allowed for statistical purposes

ITA 1383/HYD/2025[2015-16]Status: DisposedITAT Hyderabad12 Nov 2025AY 2015-16

Bench: Shri Vijay Pal Rao & Shri Manjunatha Gआ.अपी.सं /Ita Nos.1382 & 1384/Hyd./2025 िनधा"रण वष"/Assessment Years 2015-2016 & 2016-2017

For Appellant: Sri KVSSN Kumar, AdvocateFor Respondent: Dr. Sachin Kumar, Sr. AR

Section 10Section 147Section 15(1)Section 271BSection 6

Ujjaini Mahakali Devasthanam, Secunderabad vs. ITO., Exemption Ward-1(3), Hyderabad

In the result, all the six appeals of the Assessee are allowed for statistical purposes

ITA 1382/HYD/2025[2015-16]Status: DisposedITAT Hyderabad12 Nov 2025AY 2015-16

Bench: Shri Vijay Pal Rao & Shri Manjunatha Gआ.अपी.सं /Ita Nos.1382 & 1384/Hyd./2025 िनधा"रण वष"/Assessment Years 2015-2016 & 2016-2017

For Appellant: Sri KVSSN Kumar, AdvocateFor Respondent: Dr. Sachin Kumar, Sr. AR

Section 10Section 147Section 15(1)Section 271BSection 6

Ujjaini Mahakali Devathanam, Secunderbad vs. ITO., Exemption Ward-1(3), Hyderabad

In the result, all the six appeals of the Assessee are allowed for statistical purposes

ITA 1381/HYD/2025[2014-15]Status: DisposedITAT Hyderabad12 Nov 2025AY 2014-15

Bench: Shri Vijay Pal Rao & Shri Manjunatha Gआ.अपी.सं /Ita Nos.1382 & 1384/Hyd./2025 िनधा"रण वष"/Assessment Years 2015-2016 & 2016-2017

For Appellant: Sri KVSSN Kumar, AdvocateFor Respondent: Dr. Sachin Kumar, Sr. AR

Section 10Section 147Section 15(1)Section 271BSection 6

Ujjaini Mahakali Devasthanam, Secunderabad vs. ITO., Exemption Ward-1(3), Hyderabad

In the result, all the six appeals of the Assessee are allowed for statistical purposes

ITA 1380/HYD/2025[2013-14]Status: DisposedITAT Hyderabad12 Nov 2025AY 2013-14

Bench: Shri Vijay Pal Rao & Shri Manjunatha Gआ.अपी.सं /Ita Nos.1382 & 1384/Hyd./2025 िनधा"रण वष"/Assessment Years 2015-2016 & 2016-2017

For Appellant: Sri KVSSN Kumar, AdvocateFor Respondent: Dr. Sachin Kumar, Sr. AR

Section 10Section 147Section 15(1)Section 271BSection 6

Menaba Charitable Trust, Ahmedabad vs. The ITO, Ward-1(Exemptions), Ahmedabad

ITA 1361/AHD/2025[2017-18]Status: DisposedITAT Ahmedabad06 Nov 2025AY 2017-18

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyalआयकर अपील सं /Ita No.1361/Ahd/2025 िनधा"रण वष" /Assessment Year : 2017-18 Menaba Charitable Trust The Ito बनाम/ 26, Mahavir Jain Soc., Ward-1 (Exemptions) V/S. Bapunagar Ahmedabad – 380 015 Ahmedabad – 380 024 "थायी लेखा सं./Pan: Aaatm 2171 N (अपीलाथ"/ Appellant) ("" यथ"/ Respondent) Assessee By : Shri Rushin Patel, Ar Revenue By : Shri C Dharani Nath, Sr.Dr सुनवाई की तारीख/Date Of Hearing : 17/09/2025 घोषणा की तारीख /Date Of Pronouncement: 06/11/2025 आदेश/O R D E R Per Siddhartha Nautiyal, Jm: The Present Appeal Has Been Preferred By The Assessee Against The Order Of The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi [Hereinafter Referred To As ‘Cit(A)’] Dated 24/12/2024 Passed U/S.250 Of The Income Tax Act, 1961 (Hereinafter Referred To As ‘The Act’) For The Assessment Year (Ay) 2017-2018. 2. The Assessee Raised The Following Grounds Of Appeal:

For Appellant: Shri Rushin Patel, ARFor Respondent: Shri C Dharani Nath, Sr.DR

Section 11Section 115BSection 250

books of account and credited either to the income and expenditure account or to the Menaba Charitable Trust vs. ITO Asst. Year : 2017-18 corpus fund, they could not be treated as anonymous within the meaning of section 115BBC of the Act. The CIT(A), however, noted that despite issue

Shree Jagat Guru Brahmanand Gaushala Samiti, Panipat vs. CIT(E), Chandigarh

ITA 297/DEL/2022[-]Status: DisposedITAT Delhi03 Nov 2025

Bench: SHRI SATBEER SINGH GODARA (Judicial Member), SHRI NAVEEN CHANDRA (Accountant Member)

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

income of the society during the year and no tax has been paid. However, the applicant should have added the amount shown against corpus fund during the year into its income and then it should have filed the correct ITR and paid taxes. Unless the legitimate tax against the income

Ishwar Vithal Navadia, Surat vs. ITO, Ward 3(2)(1), Surat

In the result, ground No.3 of the appeal is allowed

ITA 297/SRT/2025[2013-14]Status: DisposedITAT Surat30 Oct 2025AY 2013-14

Bench: Shri Dinesh Mohan Sinha & Shri Bijayananda Prusethआयकर अपील सं./Ita No.297/Srt/2025 Assessment Year: (2013-14) (Hybrid Hearing) Ishwar Vithal Navadia Income-Tax Officer, Ward-3(2)(1), बनाम/ 201, Jaltarang Apartment, Surat, Room No.416, Aaykar Vs. Laxmi Nagar Society, Bhawan, Majura Gate, Surat-395 001 Katargam, Surat-395 004 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aakpn 1866 H (अपीलाथ"/Appellant) (""थ" /Respondent)

Section 143(3)Section 148Section 2(24)(vi)Section 250

various bench of Tribunal that where assessee was a flat owner in a housing society and he received certain sum from developer as corpus fund towards hardship cause d to flat owners on redevelopment, impugned amount would be in nature of capital receipt simplicitor not includible in income

Agrasen Medical Relief & Research Society, Jaipur vs. ITO(E), Ward-1, Jaipur

In the result, the appeal of the assessee is allowed

ITA 1026/JPR/2025[2016-17]Status: DisposedITAT Jaipur30 Oct 2025AY 2016-17

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI, AM आयकरअपीलसं./ITA No. 1026/JPR/2025 निर्धरणवर्ष / AssessmentYear : 2016-17 Agrasen Medical Relief & Research Society Central Spine, Sector -7, Vidhyadhr Nagar Jaipur - 302 039 (Raj) बनाम Vs. अपीलार्थी / Appellant स्थायीलेखा सं. / जीआईआरसं./PAN/GIR No.: AAATA 7540F The ITO (E) Ward - 1 Jaipur प्रत्यर्थी / Respondent निर्धारिती की ओरसे / Assesseeby :Shri P.C.Parwal, CA राजस्व की ओरसे /Revenue by: Shri Gautam Singh Choudh

For Appellant: Shri P.C.Parwal, CAFor Respondent: Shri Gautam Singh Choudhary, JCIT-DR

Section 11Section 12ASection 12A(1)(ac)Section 143(3)Section 194JSection 2(15)Section 80G

assessee received donation of Rs.30,19,100/- which is directly credited to 3 AGRASEN MEDICAL RELIEF & RESEARCH SOCIETY VS ITO, (E), WARD-1, JAIPUR corpus fund account. The donation receipt provided by the assessee are manipulated by inserting the word corpus fund at a later stage and therefore he considered

Shri Powai Sthanakvasi Jain Sangh Trust (Publice Charitable Trust), Mumbai vs. Income Tax Officer Ward 41(1)(4), Mumbai

In the result, grounds raised by the assessee in this respect are allowed

ITA 3187/MUM/2025[2018-19]Status: DisposedITAT Mumbai29 Oct 2025AY 2018-19

Bench: Shri Amit Shukla & Shri Girish Agrawalassessment Year: 2018-19 Shri Powai Sthanakvasi Jain Vs Income-Tax Officer, Sangh Trust Ward 41(1)(4), (Public Charitable Trust) Mumbai Flat No. 104, Atlantis A Wing Hiranandani Gardens Powai, Mumbai - 400076 [Pan: Aatts2580C] Appellant Respondent Present For: Assessee : Shri Kirit Sanghvi, Ca Revenue : Mr. Virabhadra S. Mahajan, Sr. Dr Date Of Hearing : 04.08.2025 Date Of Pronouncement : 29.10.2025 O R D E R Per Girish Agrawal: This Appeal Filed By The Assessee Is Against The Order Of Cit(A), National Faceless Appeal Centre (Nfac), Delhi Vide Order No. Itba/Nfac/S/250/2024-25/1074570665(1), Dated 17.03.2025 Passed Against The Assessment Order By National Faceless Assessment Centre, Delhi U/S.143(3) R.W.S. 144B Of The Income-Tax Act, 1961 (Hereinafter Referred To As The “Act”), Dated 31.06.2021 For Ay 2018-19. 2. The Only Issue Involved In The Present Appeal Is In Respect Of Treatment Of Corpus Fund Donation Of Rs.1,74,01,475/- Received By The 2 Shri Powai Sthanakvasi Jain Sangh Trust Ay 2018-19 Assessee During The Year As Income Chargeable To Tax Without Considering The Provisions Of Section 11(1)(D) Of The Act.

For Appellant: Shri Kirit Sanghvi, CAFor Respondent: Mr. Virabhadra S. Mahajan, Sr. DR

Section 11(1)(d)Section 12ASection 143(3)Section 80G

dated 31.06.2021 for AY 2018-19. 2. The only issue involved in the present appeal is in respect of treatment of corpus fund donation of Rs.1,74,01,475/- received by the 2 Shri Powai Sthanakvasi Jain Sangh Trust AY 2018-19 assessee during the year as income chargeable ... under consideration before us is the very first year of the assessee for assessment under the Act. Ld. AO observed that assessee had received corpus fund donation of Rs. 1,74,01,475/-. In the impugned assessment order, ld. AO made reference to the returns of the assessee filed

Shri Anandabava Sedarat Seva Sanstha Jamnagar, Jamnagar vs. CIT(Exemption), Ahmedabad

The appeal of the assessee is allowed, only for statistical

ITA 35/RJT/2025[2024-25]Status: DisposedITAT Rajkot21 Oct 2025AY 2024-25

For Appellant: Shri Mehul Ranpura, Ld. ARFor Respondent: Shri Sanjay Punglia, Ld. CIT(DR)

Section 12ASection 80GSection 80G(5)Section 80G(5)(iii)

last three years. Sr. F.Y. Total Income/ Receipts Religious Religious NO. Income as per Income expenditur expenditure Income & received Total e percentage expenditure in corpus fund