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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

Mnnit Alumni Excellence Foundation, Bangalore vs. Commissioner of Income Tax, (Exemptions), Bangalore

In the result, both the appeals filed by the assessee are allowed for statistical purposes

ITA 379/BANG/2025[2025-26]Status: DisposedITAT Bangalore25 Jun 2025AY 2025-26

Bench: Shri Laxmi Prasad Sahu & Shri Soundararajan K.

For Appellant: Shri Vaidyanathan, CAFor Respondent: Shri E. Shridhar, CIT-DR
Section 11Section 12ASection 80GSection 80G(5)

assessee also appeared in person and filed the details sought for by the Ld.CIT(E). The Ld.CIT(E) extracted the donations received, corpus funds and expenses incurred by the trust and alleged that the expenses incurred like the purchase of the lab equipment and the seminar expenses are not related ... materials available on record. 9. As seen from the impugned order of the Ld.CIT(E), the Ld.CIT(E) had extracted the donations received, corpus fund and the expenses incurred by the assessee for the last three years based on the financial statements filed by the assessee to the notice issued

Mnnit Alumni Excellence Foundation, Bangalore vs. Commissioner of Income Tax, (Exemptions), Bangalore

In the result, both the appeals filed by the assessee are allowed for statistical purposes

ITA 378/BANG/2025[2025-26]Status: DisposedITAT Bangalore25 Jun 2025AY 2025-26

Bench: Shri Laxmi Prasad Sahu & Shri Soundararajan K.

For Appellant: Shri Vaidyanathan, CAFor Respondent: Shri E. Shridhar, CIT-DR
Section 11Section 12ASection 80GSection 80G(5)

assessee also appeared in person and filed the details sought for by the Ld.CIT(E). The Ld.CIT(E) extracted the donations received, corpus funds and expenses incurred by the trust and alleged that the expenses incurred like the purchase of the lab equipment and the seminar expenses are not related ... materials available on record. 9. As seen from the impugned order of the Ld.CIT(E), the Ld.CIT(E) had extracted the donations received, corpus fund and the expenses incurred by the assessee for the last three years based on the financial statements filed by the assessee to the notice issued

Ampi Foundation, Kolkata vs. ITO, Ward 1(4), Exempt, Kolkata

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

ITA 365/KOL/2025[2022-23]Status: DisposedITAT Kolkata16 Jun 2025AY 2022-23

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishraampi Foundation, Deputy Director Of Income Unimark Asian, 16Th Floor, Tax, Cpc, Bengaluru, 52/1, Shakespeare Sarani, (Jurisdictional Assessing Kolkata - 700017 Vs Officer, Ward 1(4), (Pan: Aadta8073A) Exempt, Kolkata, 10, Middleton Row, Kolkata - 700071 (Appellant) (Respondent)

For Appellant: Siddarth Agarwal, AdvocateFor Respondent: Kallol Mistry, JCIT, Sr. DR
Section 11Section 11(1)(d)Section 12A(1)(ac)Section 12A(1)(b)Section 139(1)Section 143(1)Section 143(1)(a)Section 250

condone the delay. However, the CPC in the intimation u/s 143(1) of the Act disallowed the total donation receipts including corpus fund amounting to Rs.9,42,771/- and raised a demand of Rs.4,44,720/-. It is stated that the CPC did not consider the details filed

The Assocation of Colon and Rectal Surgeons of India, Jalandhar vs. CIT Exemptions, Chandigarh

In the result, both the appeals are dismissed

ITA 475/ASR/2024[NA]Status: DisposedITAT Amritsar09 Jun 2025

Bench: Shri Udayan Das Gupta & Shri Krinwant Sahayआयकर अपील सं./ Ita Nos. 474 & 475/Asr/2024 The Association Of Colon & बनाम The Cit Rectal Surgeons Of India, Exemption, 408A, Kapurthala Road, Chandigarh Adarsh Nagar, Jalandhar स्थायी लेखा सं./Pan No: Aakat9866E अपीलाथी/Appellant प्रत्यथी/Respondent ( Hybrid Hearing ) निर्ााररती की ओर से/Assessee By : Sh. Sushil Sharma, Advocate राजस्व की ओर से/ Revenue By : Smt. Vandana Vijay Mohite, Cit Dr सुिवाई की तारीख/Date Of Hearing : 20.03.2025 उदघोषणा की तारीख/Date Of Pronouncement : 09.06.2025 आदेश/Order Per Krinwant Sahay, Am: Appeals In These Cases Have Been Filed By The Assessee Against The Separate Orders, Each Dated 21.03.2024, Passed By Ld. Commissioner Of Income Tax, Exemptions, Chandigarh.

For Appellant: Sh. Sushil Sharma, AdvocateFor Respondent: Smt. Vandana Vijay Mohite, CIT DR

society 5. CIT (E) is wrong while making calculation of fund utilized for objects of society. 6. CIT (E) is wrong for not considering corpus fund and conditions fulfilled for same by society. 7. Any other ground which may be raised at the time of hearing

The Association of Colon and Rectal Surgeons of India, Jalandhar vs. CIT Exemption, Chandigarh

In the result, both the appeals are dismissed

ITA 474/ASR/2024[NA]Status: DisposedITAT Amritsar09 Jun 2025

Bench: Shri Udayan Das Gupta & Shri Krinwant Sahayआयकर अपील सं./ Ita Nos. 474 & 475/Asr/2024 The Association Of Colon & बनाम The Cit Rectal Surgeons Of India, Exemption, 408A, Kapurthala Road, Chandigarh Adarsh Nagar, Jalandhar स्थायी लेखा सं./Pan No: Aakat9866E अपीलाथी/Appellant प्रत्यथी/Respondent ( Hybrid Hearing ) निर्ााररती की ओर से/Assessee By : Sh. Sushil Sharma, Advocate राजस्व की ओर से/ Revenue By : Smt. Vandana Vijay Mohite, Cit Dr सुिवाई की तारीख/Date Of Hearing : 20.03.2025 उदघोषणा की तारीख/Date Of Pronouncement : 09.06.2025 आदेश/Order Per Krinwant Sahay, Am: Appeals In These Cases Have Been Filed By The Assessee Against The Separate Orders, Each Dated 21.03.2024, Passed By Ld. Commissioner Of Income Tax, Exemptions, Chandigarh.

For Appellant: Sh. Sushil Sharma, AdvocateFor Respondent: Smt. Vandana Vijay Mohite, CIT DR

society 5. CIT (E) is wrong while making calculation of fund utilized for objects of society. 6. CIT (E) is wrong for not considering corpus fund and conditions fulfilled for same by society. 7. Any other ground which may be raised at the time of hearing

Gram Vikas Educational Society, Ferozepur vs. Income Tax Officer ( Exemption), Amritsar

In the result, appeal is allowed for statistical purposes

ITA 295/ASR/2023[2017-18]Status: DisposedITAT Amritsar09 Jun 2025AY 2017-18

Bench: Shri Udayan Das Gupta & Shri Krinwant Sahayआयकर अपील सं./ Ita No. 295/Asr/2023 निर्धारण वर्ा / Assessment Year : 2017-18 Gram Vikas बनाम Ito, Educational Society, Exemption Ward, V. Pala Megha, Amritsar Ferozepur 152002 स्थधयी लेखध सं./Pan No: Aabtg7217L अपीलधथी/Appellant प्रत्यथी/Respondent

For Appellant: Sh. P.N. Arora, AdvocateFor Respondent: Sh. Manpreet Singh Duggal, Sr.DR
Section 10Section 12A

That whether the worthy CIT(A), NFAC was right in confirming addition of Rs.25,90,000/- (Twenty five Lacs ninety thousands only) under head corpus fund created in the Adarsh School Allotted by Punjab Government for providing the better administration and facility to the students of Adarsh Schools, if wrong ... 115BBE, treating it as AOP instead of the Educational Society whereas orders of CIT(E), Chandigarh was still awaited. 8. It also treated the Corpus Funds amounting to Rs.25,90,000/- shown in the balance sheet of Gram Vikas Adarsh Senior Secondary, Daulat Pura. It was allotted by Education department/PSEB

St. Josephs Institute of Science and Technology Trust, Chennai vs. DCIT, Central Circle-1(3), Chennai

ITA 3297/CHNY/2024[2020-21]Status: DisposedITAT Chennai06 Jun 2025AY 2020-21

Bench: Shri Aby T. Varkey & Shri Jagadishआयकर अपील सं./Ita Nos.3293 & 3294/Chny/2024 निर्धारणवर्ष/Assessment Year: 2018-19 & 2020-21 St. Joseph'S Educational Trust, 56-C, Old Mahabalipuram Road, Sholinganallur, Chennai-600 119. [Pan: Aamts 3888 G] (अपीलार्थी/Appellant) V. The Dcit, Central Circle-1(3), Chennai. (प्रत्यर्थी/Respondent) आयकर अपील सं./Ita Nos.3295 To 3297/Chny/2024 निर्धारणवर्ष/Assessment Year: 2018-19 To 2020-21 St. Joseph'S Institute Of Science & Technology Trust, 56-C, Old Mahabalipuram Road, Sholinganallur, Chennai-600 119. [Pan: Aahts 9943 B] (अपीलार्थी/Appellant) V. The Dcit, Central Circle-1(3), Chennai. (प्रत्यर्थी/Respondent) अपीलार्थी की ओर से/ Appellant By : Mr. V. Balaji, Ca & Mr. K.R. Vasudevan, Advocate By Virtual प्रत्यर्थी की ओर से / Respondent By : Ms. Anitha, Addl.Cit सुनवाईकीतारीख/Date Of Hearing : 04.04.2025 घोषणाकीतारीख / Date Of Pronouncement : 06.06.2025 :: 2 ::

For Appellant: Mr. V. Balaji, CA &For Respondent: Ms. Anitha, Addl.CIT
Section 11Section 12ASection 139(1)Section 143(1)Section 270ASection 271A

assessee filed RoI manually on 23.09.2021 [since there were glitches in the portal couldn't uploaded electronically] wherein assessee treated the Corpus- Fund of Rs.5,88,60,300/- as voluntary donations since donors for best reasons known to them refused to give confirmation letters. Therefore, the assessee offered gross income ... discovered that the assessee had collected capitation fees in cash, which were not accounted for in its books of accounts and were treated as corpus funds. • For A.Y. 2018-19, the AO assessed this unaccounted income to tax and initiated penalty proceedings under Section 270A. • In the penalty notice issued

St. Joshephs Institute of Science and Technology Trust, Chennai vs. DCIT, Central Circle-193), Chennai

ITA 3296/CHNY/2024[2019-20]Status: DisposedITAT Chennai06 Jun 2025AY 2019-20

Bench: Shri Aby T. Varkey & Shri Jagadishआयकर अपील सं./Ita Nos.3293 & 3294/Chny/2024 निर्धारणवर्ष/Assessment Year: 2018-19 & 2020-21 St. Joseph'S Educational Trust, 56-C, Old Mahabalipuram Road, Sholinganallur, Chennai-600 119. (Pan: Aamts 3888 G) (अपीलार्थी/Appellant) V. The Dcit, Central Circle-1(3), Chennai. (प्रत्यर्थी/Respondent) आयकर अपील सं./Ita Nos.3295 To 3297/Chny/2024 निर्धारणवर्ष/Assessment Year: 2018-19 To 2020-21 St. Joseph'S Institute Of Science & Technology Trust, 56-C, Old Mahabalipuram Road, Sholinganallur, Chennai-600 119. [Pan: Aahts 9943 B] (अपीलार्थी/Appellant) V. The Dcit, Central Circle-1(3), Chennai. (प्रत्यर्थी/Respondent) अपीलार्थी की ओर से/ Appellant By : Mr. V. Balaji, Ca & Mr. K.R. Vasudevan, Advocate By Virtual प्रत्यर्थी की ओर से /Respondent By : Ms. Anitha, Addl.Cit सुनवाईकीतारीख/Date Of Hearing : 04.04.2025 घोषणाकीतारीख / Date Of Pronouncement : 06.06.2025 :: 2 ::

For Appellant: Mr. V. Balaji, CA &For Respondent: Ms. Anitha, Addl.CIT
Section 11Section 12ASection 139(1)Section 143(1)Section 270ASection 271A

assessee filed RoI manually on 23.09.2021 [since there were glitches in the portal couldn't uploaded electronically] wherein assessee treated the Corpus- Fund of Rs.5,88,60,300/- as voluntary donations since donors for best reasons known to them refused to give confirmation letters. Therefore, the assessee offered gross income ... discovered that the assessee had collected capitation fees in cash, which were not accounted for in its books of accounts and were treated as corpus funds. • For A.Y. 2018-19, the AO assessed this unaccounted income to tax and initiated penalty proceedings under Section 270A. • In the penalty notice issued

St. Josephs Institute of Science and Technology Trust, Chennai vs. Dcot. Central Circle-1(3), Chennai

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

ITA 3295/CHNY/2024[2018-19]Status: DisposedITAT Chennai06 Jun 2025AY 2018-19

Bench: Shri Aby T. Varkey & Shri Jagadish

For Appellant: Mr. V. Balaji, CA &For Respondent: Ms. Anitha, Addl.CIT
Section 11Section 12ASection 139(1)Section 143(1)Section 270ASection 271A

assessee filed RoI manually on 23.09.2021 [since there were glitches in the portal couldn’t uploaded electronically] wherein assessee treated the Corpus- Fund of Rs.5,88,60,300/- as voluntary donations since donors for best reasons known to them refused to give confirmation letters. Therefore, the assessee offered gross income ... discovered that the assessee had collected capitation fees in cash, which were not accounted for in its books of accounts and were treated as corpus funds. • For A.Y. 2018-19, the AO assessed this unaccounted income to tax and initiated penalty proceedings under Section 270A. • In the penalty notice issued

St. Josephs Educational Trust, Chennai vs. DCIT, Central Circle-193), Chennai

ITA 3294/CHNY/2024[2020-21]Status: DisposedITAT Chennai06 Jun 2025AY 2020-21

Bench: Shri Aby T. Varkey & Shri Jagadishआयकर अपील सं./Ita Nos.3293 & 3294/Chny/2024 निर्धारणवर्ष/Assessment Year: 2018-19 & 2020-21 St. Joseph'S Educational Trust, 56-C, Old Mahabalipuram Road, Sholinganallur, Chennai-600 119. [Pan: Aamts 3888 G] (अपीलार्थी/Appellant) V. The Dcit, Central Circle-1(3), Chennai. (प्रत्यर्थी/Respondent) आयकर अपील सं./Ita Nos.3295 To 3297/Chny/2024 निर्धारणवर्ष/Assessment Year: 2018-19 To 2020-21 St. Joseph'S Institute Of Science & Technology Trust, 56-C, Old Mahabalipuram Road, Sholinganallur, Chennai-600 119. [Pan: Aahts 9943 B] (अपीलार्थी/Appellant) V. The Dcit, Central Circle-1(3), Chennai. (प्रत्यर्थी/Respondent) अपीलार्थी की ओर से/ Appellant By : Mr. V. Balaji, Ca & Mr. K.R. Vasudevan, Advocate By Virtual प्रत्यर्थी की ओर से /Respondent By : Ms. Anitha, Addl.Cit सुनवाईकीतारीख/Date Of Hearing : 04.04.2025 घोषणाकीतारीख / Date Of Pronouncement : 06.06.2025 :: 2 ::

For Appellant: Mr. V. Balaji, CA &For Respondent: Ms. Anitha, Addl.CIT
Section 11Section 12ASection 139(1)Section 143(1)Section 270ASection 271A

assessee filed RoI manually on 23.09.2021 [since there were glitches in the portal couldn't uploaded electronically] wherein assessee treated the Corpus- Fund of Rs.5,88,60,300/- as voluntary donations since donors for best reasons known to them refused to give confirmation letters. Therefore, the assessee offered gross income ... discovered that the assessee had collected capitation fees in cash, which were not accounted for in its books of accounts and were treated as corpus funds. • For A.Y. 2018-19, the AO assessed this unaccounted income to tax and initiated penalty proceedings under Section 270A. • In the penalty notice issued

St.Josephs Educational Trust, Chennai vs. DCIT, Central Circle-193), Chennai

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

ITA 3293/CHNY/2024[2018-19]Status: DisposedITAT Chennai06 Jun 2025AY 2018-19

Bench: Shri Aby T. Varkey & Shri Jagadish

For Appellant: Mr. V. Balaji, CA &For Respondent: Ms. Anitha, Addl.CIT
Section 11Section 12ASection 139(1)Section 143(1)Section 270ASection 271A

assessee filed RoI manually on 23.09.2021 [since there were glitches in the portal couldn’t uploaded electronically] wherein assessee treated the Corpus- Fund of Rs.5,88,60,300/- as voluntary donations since donors for best reasons known to them refused to give confirmation letters. Therefore, the assessee offered gross income ... discovered that the assessee had collected capitation fees in cash, which were not accounted for in its books of accounts and were treated as corpus funds. • For A.Y. 2018-19, the AO assessed this unaccounted income to tax and initiated penalty proceedings under Section 270A. • In the penalty notice issued

Moinia Hasnia Abul Ulaya Shikshan Sansthan, Kota vs. ITO Ward 1(2)(1), Bangalore

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

ITA 2618/BANG/2024[2017-18]Status: DisposedITAT Bangalore28 May 2025AY 2017-18

Bench: Shri Waseem Ahmedassessment Year: 2017-18

For Appellant: Shri Lavish Jain, CAFor Respondent: Shri Ganesh R Gale, Standing Counsel for Dept
Section 10Section 11Section 11(1)(d)Section 12ASection 143(1)Section 154

consideration, filed the return of income claiming exemption under section 10(23C)(iiiad) of the Act. The assessee, in the return of income, showed corpus fund donation amounting to ₹21,87,961.00 which was treated as income by the CPC in the intimation generated under section ... reasoning that the assessee claimed exemption of the corpus fund under section 11 of the Act, whereas the assessee has not been registered under section 12AA of the Act. The assessee filed an application for rectification under section 154 of the Act against the intimation, but the same was rejected

Shree Mahaveer Research Foudation, Pune vs. DCIT(Exemption) (Hq), Pune

In the result, appeal of the assessee is Partly Allowed

ITA 792/PUN/2025[2011-12]Status: DisposedITAT Pune27 May 2025AY 2011-12

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.792/Pun/2025 िनधा"रण वष" / Assessment Year: 2011-12 Shree Mahaveer Research V The Dcit(Exemption) Foundation, S (Hq), Pune. 1183/ C/O.Vijayraj Ranka, G C Jewellers, Raviwar Peth, Pune – 411002. Maharashtra. Pan: Aadts7800B Appellant/ Assessee Respondent / Revenue Assessee By Shri Nikhil Pathak – Ar Revenue By Shri Madhan Thirmanpallil – Addl.Cit(Dr) – Virtual Hearing. Date Of Hearing 14/05/2025 Date Of Pronouncement 27/05/2025

Section 11Section 12ASection 143(3)Section 148Section 250

under : “5. The assessment of receipts of the Trust are brought to tax as the assessee's income of Rs.22,08,407/- being corpus fund which is rightly added to the total income of the Trust. The status of the assessee is AOP. Addition of corpus donation of Rs.22

Dudhsagar Research and Development Association, Mehsana vs. The DCIT(E) Circle-1, Ahmedabad

In the result, the appeal of the assessee is allowed

ITA 1048/AHD/2023[2014-15]Status: DisposedITAT Ahmedabad26 May 2025AY 2014-15

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

For Appellant: Shri S. N. Soparkar, Sr. Advocate & Shri ParinFor Respondent: Shri V Nandakumar, CIT DR
Section 271(1)(c)

voluntary in nature”, as stated by the assessee and mere production of receipts which state that the amount has been paid towards “corpus fund of the assessee” cannot lead to the conclusion that the contribution qualifies as “corpus donation”, more so, when the receipts do not even state the specific ... writing that they are “voluntary” donations. The Counsel for the assessee submitted the practice of receiving and treating such donation as contributions to the “corpus fund” of the assessee trust has been prevalent for more than 15 years to 20 years. Further, it was submitted that the books of accounts

Assistant Commissioner of Income Tax, Exemption Circle, Aurangabad, Near Holy Cross English School vs. The Nanded Sikhgurudwara Sachkhand Hazur Sahib, Abchalnagar

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

ITA 809/PUN/2024[2017-18]Status: DisposedITAT Pune26 May 2025AY 2017-18

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

For Appellant: Shri Nikhil S PathakFor Respondent: Shri Amol Khairnar CIT-DR
Section 10Section 139Section 143(2)

assessee generated surplus of Rs.28,02,93,045/-. From the balance sheet of the assessee, the Assessing Officer observed that the assessee had corpus fund of Rs.1,59,51,94,751/- and FDRs of Rs.1,33,28,20,331/-. He noted that the surplus to net receipt ratio for various

Assistant Commissioner of Income Tax, Exemption Circle, Aurangabad, Near Holy Cross English School vs. The Nanded Sikhgurudwara Sachkhand Hazur Sahib, Apchalnagar

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

ITA 808/PUN/2024[2016-17]Status: DisposedITAT Pune26 May 2025AY 2016-17

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

For Appellant: Shri Nikhil S PathakFor Respondent: Shri Amol Khairnar CIT-DR
Section 10Section 139Section 143(2)

assessee generated surplus of Rs.28,02,93,045/-. From the balance sheet of the assessee, the Assessing Officer observed that the assessee had corpus fund of Rs.1,59,51,94,751/- and FDRs of Rs.1,33,28,20,331/-. He noted that the surplus to net receipt ratio for various

ACIT, Exemption Circle, Ranchi vs. M/S. R.V.S. Educational Trust, Jamshedpur

In the result, appeal of the revenue is dismissed

ITA 24/RAN/2020[16-17]Status: DisposedITAT Ranchi21 May 2025

Bench: Shri George Mathan, Jm & Shri Ratnesh Nandan Sahay, Am (Through : Hybrid Mode) आयकरअपीलसं./Ita No.24/Ran/2020 (Ǔ""ȡ[""""[/ A.Y. :2016-2017) Acit, Exemption Circle, Ranchi Vs. M/S Rvs Educational Trust, C/O Binda Apartments (India) Private Limited, Siroman Nagar, Dimna Road, Mango, Jamshedpur-831012 ̾Ĉĭēıĕĸù Ĭĝń/Pan No. : Aaatr4456M (\ "Ȣ"ȡ"ȸ/Appellant) (Ĥ×""ȸ/ Respondent) ..

For Appellant: Shri Shikesh Jha, ARFor Respondent: Shri Shiv Swaroop Singh, CIT-DR
Section 11(1)(d)Section 12ASection 143(3)

same is reflected on the Liability Side and it is not allowable by virtue of provisions of Sec.11(1)(d) of the Act, Since corpus fund dose not form part of 'total income', therefore expenditure out of corpus fund will not be a part of application of income ... current year income. The Ld. A.O. has mentioned in the assessment order that we have paid the installment of the loan out of corpus fund, borrowed fund, sundry creditors, form loan, form accumulated fund. But the fact is that we have not received any corpus fund during the F/Y2015-16

DCIT Exmp Circle Pune, Swargate Pmt Bldg vs. Ashirwad Charitable Trust, Mumbai

In the result, the appeal filed by the Revenue in ITA

ITA 225/PUN/2024[2014]Status: DisposedITAT Pune16 May 2025

Bench: Shri Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.224 & 225/Pun/2024 िनधा"रण वष" / Assessment Year : 2014-15 Dcit (Exemptions) Circle, Vs. Ashirwad Charitable Pune. Trust, 402, Pascal Martin Road, Regent Chambers, Nariman Point, Mumbai- 400021. Pan : Aabta4479Q Appellant Respondent Revenue By : Shri Ramnath P. Murkunde Assessee By : Shri Raja B. Singh & Mohd. Obaid Ansari Date Of Hearing : 18.02.2025 Date Of Pronouncement : 16.05.2025 आदेश / Order Per Vinay Bhamore, Jm: Both The Above Captioned Appeals Filed By The Revenue Are Directed Against The Separate Orders Dated 06.12.2023 Passed By Ld. Cit(A)/Nfac For The Assessment Year 2014-15 Respectively. 2. Since The Facts Are Identical & Both The Above Captioned Appeals Were Heard Together, Therefore, We Proceed To Dispose Of The Same By This Common Order. 3. First, We Shall Take Up The Appeal In Ita No.224/Pun/2024 For Adjudication.

For Appellant: Shri Raja B. Singh &For Respondent: Shri Ramnath P. Murkunde
Section 11Section 12ASection 2(15)Section 3Section 5

deleting the addition of Rs.4,93,72,616/- which was made to the total income by considering the requirements for transparency and accountability in corpus fund management. 5. The appellant craves leave to add, alter or amend any or all the grounds of appeal.” 5. Facts of the case

Dy Commissioner of Income Tax Exmp Circle Pune, Swargate Pmt Bldg vs. Ashriwad Charitable Trust, Mumbai

In the result, the appeal filed by the Revenue in ITA

ITA 224/PUN/2024[2014]Status: DisposedITAT Pune16 May 2025

Bench: Shri Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.224 & 225/Pun/2024 िनधा"रण वष" / Assessment Year : 2014-15 Dcit (Exemptions) Circle, Vs. Ashirwad Charitable Pune. Trust, 402, Pascal Martin Road, Regent Chambers, Nariman Point, Mumbai- 400021. Pan : Aabta4479Q Appellant Respondent Revenue By : Shri Ramnath P. Murkunde Assessee By : Shri Raja B. Singh & Mohd. Obaid Ansari Date Of Hearing : 18.02.2025 Date Of Pronouncement : 16.05.2025 आदेश / Order Per Vinay Bhamore, Jm: Both The Above Captioned Appeals Filed By The Revenue Are Directed Against The Separate Orders Dated 06.12.2023 Passed By Ld. Cit(A)/Nfac For The Assessment Year 2014-15 Respectively. 2. Since The Facts Are Identical & Both The Above Captioned Appeals Were Heard Together, Therefore, We Proceed To Dispose Of The Same By This Common Order. 3. First, We Shall Take Up The Appeal In Ita No.224/Pun/2024 For Adjudication.

For Appellant: Shri Raja B. Singh &For Respondent: Shri Ramnath P. Murkunde
Section 11Section 12ASection 2(15)Section 3Section 5

deleting the addition of Rs.4,93,72,616/- which was made to the total income by considering the requirements for transparency and accountability in corpus fund management. 5. The appellant craves leave to add, alter or amend any or all the grounds of appeal.” 5. Facts of the case

Guru Nanak Modern School, Kanpur vs. AO, NFAC, Kanpur

In the result, the appeal of the assessee is dismissed as withdrawn

ITA 393/LKW/2024[2018-19]Status: HeardITAT Lucknow14 May 2025AY 2018-19

Bench: Shri Kul Bharat & Shri Anadee Nath Misshraguru Nanak Modern School Assessing Officer V. 79/7, Latouche Road, Kanpur- National E-Assessment Centre 208001 (U.P.)(H.O) Guru Nanak Modern School Income Tax Office, Civic Bthoor Road Kalyanpur, Centre, Minto Road, Kanpur-208017. Delhi/Aayakar Bhawan, 16/69, Civil Lines, Kanpur-208001. Pan:Aaatg9956B (Appellant) (Respondent) Appellant By: Shri Rakesh Garg, Adv Respondent By: Shri Puneet Kumar, Cit(Dr) Date Of Hearing: 07 05 2025 Date Of Pronouncement: 14 05 2025 O R D E R

For Appellant: Shri Rakesh Garg, AdvFor Respondent: Shri Puneet Kumar, CIT(DR)
Section 11Section 250Section 250(4)

justified to treat the admission fees and development fees amounting to Rs 6234000/as regular fees instead of one time capital receipts and part of Corpus fund and not the current income of the appellant. 7. The learned CIT(A) as well as learned AO are not justified to treat