M/S. MAHASAKTI FOUNDATION,KALAHANDI vs. ACIT, SAMBALPUR
In the result, the appeals filed by the assessee are allowed
ITA 134/CTK/2015[2007-08]Status: DisposedITAT Cuttack06 Jun 2017AY 2007-08
Bench: S/Shri N.S Saini & Pavan Kumar Gadale
For Appellant: Shri P.K.Mishra, ARFor Respondent: Shri Kunal Singh, CIT DR
Section 11Section 12ASection 147Section 194ASection 201(1)Section 40
173, wherein Paragraphs 24 and 25 clearly define the scope of the amendment wherein in paragraph 25(i) , the concluding sentence is as under:-
“contributions received with a specific direction that they will form part of the corpus of the trust or distribution will, however, not be regarded as income.”
Thus the relevant clause defining income in section