Temporary donations to other charitable entities did not violate spirit of Section 11

CIT (Exemptions) Vs Jamnalal Bajaj Foundation (Delhi High Court)

The case of CIT (Exemptions) vs. Jamnalal Bajaj Foundation, as adjudicated by the Delhi High Court, revolves around the interpretation and application of provisions under Section 11 of the Income Tax Act, which pertain to income derived from property held under trust for charitable or religious purposes. Here’s a comprehensive summary of the key aspects and arguments presented in the case:

Background and Arguments:

1. Initial Assertion by the Assessee: The Jamnalal Bajaj Foundation contended that a surplus of accumulated income, amounting to INR 20 crores, was temporarily donated to other charitable institutions for a period of less than two months. They argued that this temporary diversion should not disqualify them from claiming exemption under Section 11(2) of the Income Tax Act. They sought permission to accumulate 15% of the deemed income arising from this temporary donation.

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