Corpus Donations Cannot Be Taxed If Written Direction Exists: ITAT Mumbai

Powai Sthanakvasi Jain Sangh Trust Vs ITO (ITAT Mumbai)

ITAT Mumbai: Corpus Donations with Written Directions Exempt u/s 11(1)(d) – Addition of ₹1.74 Crore Deleted

Assessee, a registered charitable trust u/s 12AA & 80G, received ₹1.74 crore as corpus donations from 76 donors with written directions for the “building fund”. AO taxed it as income, holding that no charitable activity was carried out during the year. CIT(A) upheld this view.

Tribunal held that once donations are received with specific directions to form part of the corpus, t

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