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“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
73
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
48
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
42
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
33
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
26
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
20
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
17
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

ACIT (Exemption) Circle 1 Ahmedabad, Ahmedabad vs. Dr K R Shroff Foundation, Ahmedabad

ITA 1205/AHD/2025[2018-19]Status: DisposedITAT Ahmedabad05 Aug 2025AY 2018-19

Bench: Shri T.R. Senthil Kumar & Shri Narendra Prasad Sinha

Section 11Section 12ASection 143(3)Section 147Section 68

ITA Nos.1205 & 769/Ahd/2025 Assessment Years: 2018-19 ACIT(E) vs. Dr. KR Shroff Foundation Page 1 of 24 IN THE

M/S.Believers Eastern Church, Thiruvalla vs. The CIT (Exemption), Kochi

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

ITA 15/COCH/2021[2020-21]Status: DisposedITAT Cochin04 Aug 2025AY 2020-21

Bench: Shri Inturi Rama Rao, Am & Shri Sonjoy Sarma, Jm

For Appellant: Shri B. Ramakrishnan, &For Respondent: Smt. Veni Raj, CIT-DR
Section 11Section 12ASection 13Section 132

Income filed by the Trusts/Entities are Incorrect and Incomplete 4 ITA No. 12-15/Coch/2021 Last Hour Ministry & Ors. c) Expenses out of corpus fund have been claimed towards application d) Amounts set apart for specific purposes are found to have been indiscriminately and improperly used e) Expenditures incurred have ... correctness of the income computation. Copy of the Assessment Orders are enclosed at pages 53 to 58 of the paperbook. c) Allegation: Expenses from corpus funds claimed as application Corpus donations were specifically excluded from income computation and no such expense has been treated as application. CIT(E) has failed

Ayana Charitable Trust, Thiruvalla vs. DCIT(Exemption), Trivandrum

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

ITA 14/COCH/2021[2020-21]Status: DisposedITAT Cochin04 Aug 2025AY 2020-21

Bench: Shri Inturi Rama Rao, Am & Shri Sonjoy Sarma, Jm

For Appellant: Shri B. Ramakrishnan, &For Respondent: Smt. Veni Raj, CIT-DR
Section 11Section 12ASection 13Section 132

Income filed by the Trusts/Entities are Incorrect and Incomplete 4 ITA No. 12-15/Coch/2021 Last Hour Ministry & Ors. c) Expenses out of corpus fund have been claimed towards application d) Amounts set apart for specific purposes are found to have been indiscriminately and improperly used e) Expenditures incurred have ... correctness of the income computation. Copy of the Assessment Orders are enclosed at pages 53 to 58 of the paperbook. c) Allegation: Expenses from corpus funds claimed as application Corpus donations were specifically excluded from income computation and no such expense has been treated as application. CIT(E) has failed

Love India Ministries, Thiruvalla vs. The DCIT(Exemption), Kochi

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

ITA 13/COCH/2021[2020-21]Status: DisposedITAT Cochin04 Aug 2025AY 2020-21

Bench: Shri Inturi Rama Rao, Am & Shri Sonjoy Sarma, Jm

For Appellant: Shri B. Ramakrishnan, &For Respondent: Smt. Veni Raj, CIT-DR
Section 11Section 12ASection 13Section 132

Income filed by the Trusts/Entities are Incorrect and Incomplete 4 ITA No. 12-15/Coch/2021 Last Hour Ministry & Ors. c) Expenses out of corpus fund have been claimed towards application d) Amounts set apart for specific purposes are found to have been indiscriminately and improperly used e) Expenditures incurred have ... correctness of the income computation. Copy of the Assessment Orders are enclosed at pages 53 to 58 of the paperbook. c) Allegation: Expenses from corpus funds claimed as application Corpus donations were specifically excluded from income computation and no such expense has been treated as application. CIT(E) has failed

Last Hour Ministry, Thiruvalla vs. ACIT(Exemption), Kochi

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

ITA 12/COCH/2021[2020-21]Status: DisposedITAT Cochin04 Aug 2025AY 2020-21

Bench: Shri Inturi Rama Rao, Am & Shri Sonjoy Sarma, Jm

For Appellant: Shri B. Ramakrishnan, &For Respondent: Smt. Veni Raj, CIT-DR
Section 11Section 12ASection 13Section 132

Income filed by the Trusts/Entities are Incorrect and Incomplete 4 ITA No. 12-15/Coch/2021 Last Hour Ministry & Ors. c) Expenses out of corpus fund have been claimed towards application d) Amounts set apart for specific purposes are found to have been indiscriminately and improperly used e) Expenditures incurred have ... correctness of the income computation. Copy of the Assessment Orders are enclosed at pages 53 to 58 of the paperbook. c) Allegation: Expenses from corpus funds claimed as application Corpus donations were specifically excluded from income computation and no such expense has been treated as application. CIT(E) has failed

Kalyan Charity Trust, Pune vs. CIT (Exemp), Pune

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

ITA 946/PUN/2025[2024-25]Status: DisposedITAT Pune31 Jul 2025AY 2024-25

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

For Appellant: Shri S.M. BandiFor Respondent: Shri Amol Khairnar
Section 80Section 80GSection 80G(5)Section 80G(5)(vi)

donation, receipt no. etc. Also furnish the copies of receipt issued to the donors by your trust. (iii) There has been addition to corpus funds. Nature and source of the same has not been explained. In case the same being donations, details of donations with full name, address

Nampalli Temple Trust, Kandi Village vs. ITO., Ward-11(1), Hyderabad

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

ITA 793/HYD/2025[2024-25]Status: DisposedITAT Hyderabad31 Jul 2025AY 2024-25

Bench: Shri Manjunatha G & Shri Ravish Sood

For Appellant: CA, RajsekharFor Respondent: MS. U Mini Chandran, CIT-DR
Section 12A

case are that, the assessee is a Public Charitable Trust was established on 23.09.2009 and engaged in maintenance of Saraswati Devi Temple with Corpus Fund which was inaugurated on 24.06.2010 by general public and devotees. The Trust is occasionally conducts medical camps for general public as a measure of charity ... record and the orders of the authorities below. The appellant-trust is a Public Charitable Trust engaged in maintenance of Saraswati Devi Temple with Corpus Fund and was established on 23.09.2009. The assessee trust also conducts occasionally free medical camps for general public as a measure of charity work sponsored

Dilkhos Memorial Trust, Kolkata vs. ITO, Ward 1(2)(Exemption), Kolkata

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

ITA 558/KOL/2025[2019-20]Status: DisposedITAT Kolkata31 Jul 2025AY 2019-20

Bench: Shri Duvvuru Rl Reddy, Vice-(Kz) I.T.A. No. 558/Kol/2025 Assessment Year: 2019-2020 Dilkhos Memorial Trust,…….………..………Appellant 97, Trimurti Apartment, Park Street, Kolkata-700016, W.B. [Pan:Aabtd7407R] -Vs.- Income Tax Officer,……………………………..Respondent Ward-1(2), (Exemption), Kolkata, 10B, Middleton Row, Kolkata-700069 Appearances By: Shri Anil Kochar, Advocate, Appeared On Behalf Of The Assessee Shri Susanta Saha, Addl. Cit, Sr. D.R., Appeared On Behalf Of The Revenue Date Of Concluding The Hearing: June 26, 2025 Date Of Pronouncing The Order: July 31, 2025 O R D E R

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

08/10/2007 vide Approval No. DITE8E5040708182123 by DITE, Kolkata. The assessee-Trust filed its return of income on 31/10/2019 showing voluntary contributions other than corpus fund of Rs.3,46,450 and interest income by Rs. 1,02,267.00 respectively aggregating to Rs.4,48,717.00 as against actual expenses on the education ... assessable income. 4. At the time of hearing, ld. Counsel for the assessee contended that during the year under consideration, voluntary contributions other than corpus fund of Rs.3,46,450/- and interest income of Rs.1,02,267/- was received, and total aggregating income of Rs.4,48,717/- was accrued

Bastuhara Sahayata Samiti, Kolkata vs. ITO, Ward 1(2)(Exemption), Kolkata

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

ITA 444/KOL/2025[2016-17]Status: DisposedITAT Kolkata28 Jul 2025AY 2016-17

Bench: Shri Duvvuru Rl Reddy, Vice-(Kz) I.T.A. No. 444/Kol/2025 Assessment Year: 2016-2017 Bastuhara Sahayata Samiti,……………….…Appellant 27/1B, Bidhan Sarani, Srimini Market, Kolkata-700006, West Bengal [Pan:Aaatb7422R] -Vs.- Income Tax Officer,……………………………..Respondent Ward-1(2), (Exemption), Kolkata, Office Of The Income Tax Officer, 10B, Middleton Row, Kolkata-700071 Appearances By: Shri S.K. Tulsian, Advocate & Ms. Puja Somani, C.A., Appeared On Behalf Of The Assessee Shri Somnath Das Biswas, Sr. D.R., Appeared On Behalf Of The Revenue Date Of Concluding The Hearing: May 20, 2025 Date Of Pronouncing The Order: July 28, 2025 O R D E R

Section 119(2)(b)Section 12ASection 142(1)Section 143(2)Section 143(3)

claim has not mentioned in the ITR 7 and in the resolution passed in the Executive Committee meeting, the fund was set apart as Corpus Fund. As such, the claim of donation of Rs.32,33,240/- as corpus in nature that has been capitalized was rejected and the amount ... stage, it is reiterated that as per Resolution of the Board of Trustees, the society made a public appeal with specific purpose of raising corpus fund from donors across India to help/assist the natural calamity victims and requested to send the donations directly to the bank account of the society

Sri Gmh Harity Foundation, Davanagere vs. The Income Tax Officer- Exemption (Exemption Ward-1), Hubballi

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

ITA 442/BANG/2025[2025-26]Status: DisposedITAT Bangalore28 Jul 2025AY 2025-26

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Sri Ramanagowda S Gowdar, A.RFor Respondent: Sri E. Shridhar, D.R
Section 12ASection 80G

above, the ld. CIT(E) held that as the assessee did not furnish the documents for establishment of oxygen plant where trust received huge corpus funds and for the charitable activities, the genuineness of the charitable activities can’t be proved and hence the ld. CIT(E) rejected the application

Sri Gmh Harity Foundation, Davanagere vs. The Income Tax Officer, Exemption, Exemption Ward-1, Hubballi

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

ITA 441/BANG/2025[2025-26]Status: DisposedITAT Bangalore28 Jul 2025AY 2025-26

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Sri Ramanagowda S Gowdar, A.RFor Respondent: Sri E. Shridhar, D.R
Section 12ASection 80G

above, the ld. CIT(E) held that as the assessee did not furnish the documents for establishment of oxygen plant where trust received huge corpus funds and for the charitable activities, the genuineness of the charitable activities can’t be proved and hence the ld. CIT(E) rejected the application

Kowshika Sankethi Sangha, Bangalore vs. Income Tax Officer, Ward-1, Exemptions, Bangalore

Accordingly the appeal filed by the assessee is allowed for statistical purposes

ITA 880/BANG/2025[2018-19]Status: DisposedITAT Bangalore25 Jul 2025AY 2018-19

Bench: Shri Prashant Maharishi & Shri Soundararajan K.Assessment Year : 2018-19

For Appellant: S/Shri C R Krishna & Sachin Mehta, CAsFor Respondent: Shri Shivanand H Kalakeri, CIT(DR)(ITAT), Bengaluru
Section 11Section 11(1)Section 11(1)(a)Section 11(1)(d)Section 12ASection 143(1)Section 80G(5)

time of filing of return of income, assessee submitted that a sum of Rs.72,14,721 is the voluntary contribution forming part of the corpus fund and therefore it is exempt under the provisions of section 11(1)(d) of the Act. While processing the return, the CPC has considered

Nnf State Chapter Telangana, Hyderabad vs. Income Tax Officer (Exemption), Ward 1(2), Hyderabad

In the result, the appeal is allowed for statistical purposes

ITA 152/HYD/2025[2020-21]Status: DisposedITAT Hyderabad18 Jul 2025AY 2020-21

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.152/Hyd/2025 (निर्धारण वर्ा/Assessment Year:2020-21) M/S. Nnf State Chapter Telangana, Income Tax Officer Vs. Hyderabad. (Exemptions), Pan: Aaean1771C Ward-1(2), Hyderabad. (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Shri M.V. Anil Kumar, C.A. रधजस् व द्वधरध/Revenue By: Ms. G. Saratha, Sr-Dr सुिवधई की तधरीख/Date Of Hearing: 16/07/2025 घोर्णध की तधरीख/Pronouncement: 18/07/2025 आदेश/Order Per Madhusudan Sawdia, A.M. : This Appeal Is Filed By M/S. Nnf State Chapter Telangana (“The Assessee”), Feeling Aggrieved By The Order Passed By The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi (“Ld. Cit(A)”), Dated 20.11.2024 For The A.Y. 2020-21. 2. The Assessee Has Raised The Following Grounds Of Appeal :

For Appellant: Shri M.V. Anil Kumar, C.AFor Respondent: Ms. G. Saratha, SR-DR
Section 11Section 143(2)Section 143(3)Section 144B

society had organised a medical conference and ITA No.152/Hyd/2025 4 collected Rs.1,000/- from each participant, out of the participation fee, specifically towards a corpus fund for purchase of neonatal equipment to be installed at the hospital and to be utilised for the treatment of new born babies and neonate ... sample receipts placed at page nos. 110 to 189 of the paper book, on which a separate seal containing the words “Rs.1000/- towards corpus fund” has been affixed. The Ld. AR contended that such affixation itself signifies the intention of the donor towards corpus fund. The Ld. AR also submitted

Loknayak Jaiprakash Narayan Leprosy Eradication Trust, Mumbai vs. Income Tax Officer Exem Ward 1(4), Mumbai

In the result, grounds of appeal raised by assessee is allowed

ITA 2827/MUM/2025[2011-12]Status: DisposedITAT Mumbai18 Jul 2025AY 2011-12

Bench: Shri Pawan Singh(Physical Hearing) Loknayakjaiprakash Narayan Leprosy Ito Exemption Ward-1(4), Room No. 216, 2Nd Floor, Eradication Trust Vs Plot No. 16, Krishna Kunj, J.P. Nagar Mtnl Building, Peddar Road, Road No. 3, Goregaon East, Cumball Hill, Mumbai-400063. Mumbai-400026. [Pan No. Aaatl0220B] Appellant / Assessee Respondent / Revenue

Section 11(1)(d)Section 12ASection 147Section 148Section 250Section 254(1)

Karnataka High Court in Bharatiya Sanskriti Vidyapeeth Trust in ITA No. No. 278 of 2007 held that donation for specific fund and purpose constitute corpus fund. Similarly, Gujarat High Court in CIT Vs Sir Plot Swetambara Murti Pujak Jain Mandal 211 ITR 293 also held that contribution for specific purpose ... receipts but fact remains the same that such donation is made for the purpose of activities of assessee trust. Therefore, treatment of such corpus fund as a general is not justified. Thus, I direct the assessing officer to treat the impugned donation of Rs. 10,21,500/- is ‘corpus donation

Virendra Prakash Sharma, Jaipur vs. DCIT Circle (Intl Tax), Jaipur

In the result, the appeal of the assessee is allowed

ITA 286/JPR/2025[2020-21]Status: DisposedITAT Jaipur16 Jul 2025AY 2020-21
For Appellant: Shri Rajeev Sogani, CA &For Respondent: Smt. Runi Pal, CIT (Th. VC)
Section 132Section 143(3)Section 144C(13)Section 144C(5)Section 153CSection 69

flat. The break-up of which is as under: | Particulars Basic Selling Price (Excluding GST) Less: Rebate for impact assessment (Discount) Add: Corpus Fund Deposit (Rs.250 per sq. ft x 5,600 sq. ft) Add: Deposit for Maintainence (Rs.50 per sq. ft x 5,600 sq. ft) Total Consideration (Excluding ... page 33 of the paper book ] reads as under : | Particulars Basic Selling Price (Excluding GST) Less: Rebate for impact assessment (Discount) Add: Corpus Fund Deposit (Rs.250 per sq. ft x 5,600 sq. ft) Add: Deposit for Maintainence (Rs.50 per sq. ft x 5,600 sq. ft) Total Consideration (Excluding

Muslim Foundation for Renaissance Kolhapur, Kolhapur vs. Jurisdictional AO, Exemption Ward, Kolhapur

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

ITA 1046/PUN/2025[2021-22]Status: DisposedITAT Pune14 Jul 2025AY 2021-22

Bench: Dr.Manish Borad

For Appellant: Ms. Chaitee LondheFor Respondent: Shri Deepak Kumar Kedia
Section 11Section 12ASection 143(1)(a)Section 250

closing balance of corpus donation as on 31.03.2024 at Rs.41,96,493/- as the corpus donation received during the year. The account of corpus fund placed before me is as under : Opening balance of Corpus Fund as on 1 April Rs.33,99,000/- 2020 as per the Balance sheet Corpus ... donations received during the year Rs.7,97,493/- Closing balance of Corpus Fund as on 31 Rs.41,96,493/- March 2021 as per the Balance sheet 12. In place of corpus donation received at Rs.7,97,493/-, the figure mentioned in the income-tax return is Rs.41,96,493/-. Further

Odia Samaj, Aradhna Enclave vs. Income-Tax Officer (Circle Exemp 2(1), Delhi), New Delhi

ITA 5251/DEL/2024[2018-19]Status: DisposedITAT Delhi09 Jul 2025AY 2018-19

Bench: Ms. Madhumita Roy & Shri Manish Agarwalassessment Year: 2018-19

Section 11Section 12ASection 142(1)Section 143(2)Section 143(3)Section 144BSection 80G(5)(vi)

towards corpus of the trust during the year under consideration. 5 ODIA Samaj v. ITO A.Y. 2018-19 7. On 18.01.2021 following details of corpus fund received by the assessee was provided to the Ld. AO: Sl. No. Name of the person who has given corpus fund Amount ... Covid-19 period was there, the letters of the Public Sector Units making specific directions for consideration of the donated funds as corpus fund should have been handed over to the assessee trust during that period. 6 ODIA Samaj v. ITO A.Y. 2018-19 However, in the absence of such

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

ITA 777/IND/2024[-]Status: DisposedITAT Indore08 Jul 2025

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

Section 12ASection 80GSection 80G(5)

impugned order) in an attempt to show that the receipt issued by assessee contained separate boxes for ticking (i) normal charity or (ii) corpus fund. It was further submitted that the donors gave verbal/telephonic instructions for utilization towards (i) normal charity or (ii) to be held as corpus and accordingly

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)

impugned order) in an attempt to show that the receipt issued by assessee contained separate boxes for ticking (i) normal charity or (ii) corpus fund. It was further submitted that the donors gave verbal/telephonic instructions for utilization towards (i) normal charity or (ii) to be held as corpus and accordingly

Ram Parsad Dav Public School Society, Markanda vs. ITO (Exemptions), Ward, Ambala

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

ITA 752/CHANDI/2022[2016-17]Status: DisposedITAT Chandigarh30 Jun 2025AY 2016-17

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. MANOJ KUMAR AGGARWAL (Accountant Member)

For Appellant: Shri Vibhor Garg, C.AFor Respondent: Dr. Ranjit Kaur, Addl. CIT, Sr. DR
Section 10Section 11(1)(d)Section 12ASection 143(3)Section 2(24)(iia)Section 250(4)Section 250(6)Section 251(2)Section 271(1)(c)

running a school in Shahabad Markanda, Haryana, filed a Nil income return for A.Y. 2016-17, claiming a Rs. 2,52,325/- donation as "Corpus Fund" and a net surplus of Rs. 20,97,794/- as exempt under Section 10(23C)(vi). The Assessing Officer (AO), during scrutiny under Section