Vishranthi Trust Vs ITO (ITAT Bangalore)
Donor Names Alone Will Not Do: ITAT Sends ₹48.94 Lakh Anonymous Donation Addition Back for Verification
A charitable trust may know who gave it money, but can it establish that a donation is not anonymous without maintaining the donor’s address? The Bengaluru ITAT considered this question in Vishranthi Trust v. ITO (Exemptions), where the Assessing Officer (AO) had initially treated more than ₹1.60 crore of receipts as anonymous donations under section 115BBC.
The first appellate authority reduced the disputed amount to ₹48,93,933. Before the ITAT, the trust sought another opportunity to produce supporting records. The Tribunal granted that opportunity by sending the remaining addition back to the AO for verification. It made clear, however, that the burden of furnishing the donors’ names and addresses rests with the trust. The addition will be deleted only if the AO finds that section 115BBC has been complied with.
How the dispute began
Vishranthi Trust filed its return for assessment year 2017–18 declaring nil income after claiming exemption under sections 11 and 12. During scrutiny, the AO sought details of receipts shown as donations, totalling approximately ₹2 crore. The trust was asked to provide particulars of corpus and non-corpus donors, including names, addresses, contact numbers, PANs and modes of receipt.
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