ITAT Restores Corpus-Donation Dispute: Non-Speaking Order Set Aside for Fresh Adjudication

KJSL Foundation Vs ITO (ITAT Delhi) In this appeal, Assessee challenged the addition of ₹10 lakh made u/s 115BBI on alleged taxable donations while processing the return u/s 143(1). Assessee claimed the amount was corpus donation exempt u/s 11(1)(d), but no evidence or explanation was furnished before AO or before Addl/JCIT(A), who therefore upheld the addition through a non-speaking order, merely stating that Assessee failed to substantiate the corpus nature of the receipt. Tribunal noted that the appellate authority did not examine the merits, nor verify whether the donations carried speci...