In the result, all the appeals filed by the revenue for the
Bench: Shri V. Durga Rao & Shri D.S. Sunder Singh
b) Section 2(24)(ii- a) deems revenue contributions to be income of the trust. It thereby prevents the trust from claiming exemption under general law on the ground that such contributions stand on the same footing as gifts and are therefore not taxable. (See under Section 10(3), "Voluntary payments ..."p.320.) (c) Section 12 goes one step further