In the result, both the appeals are dismissed
Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria
capital receipt. Accordingly, section 115BBE is not applicable on the assessee. On the basis of the above submissions, it is very clear that the Ld. Assessing Officer has erred both on the facts as well as in law in treating the corpus donation as income u/s 2(24) and making the addition u/s 68 . The order passed is not tenable