Absence of intention in donation receipt cannot convert corpus donation in Income

Donor’s stipulation to start a college in his grandfather’s name was sufficient to treat donation as ‘corpus’ Case of the revenue is that the intention of the donor apart from the gift deed not to be seen for concluding that it was a corpus donation. On the other hand, case of the assessee is that if discussion between the donor and the donee in the shape of correspondence etc. is seen then it would reveal that donation was made by the donor in order to establish an engineering and a management college in the name of his grand-father. The donor has specifically mentione...