Opening Balance Can’t Be Taxed Again & Corpus Fails Only Where Proof Fails – Revenue Routed

ITO Vs Veer Kunwar Singh Shodh Sansthan (ITAT Delhi) ITAT Delhi dismissed the Revenue’s appeal for AY 2018-19 in Veer Kunwar Singh Shodh Sansthan, affirming CIT(A)’s order granting substantial relief to the charitable trust. On the Building Fund, the Tribunal held that ₹2.92 crore was a pure opening balance as on 01.04.2018, accumulated over more than a decade. Since the amount did not arise in the relevant AY, its addition was wholly unsustainable. The AO had not carried out any investigation into year-wise accretions despite details being furnished; taxing an opening balance in the cur...