Students Contribution for Building Development Fund is capital receipt

Vidya Bharati Society for Education & Scientific Advancement Vs ACIT (ITAT Kolkata)

Merely because the contributions from students were collected under the nomenclature of development fee cannot ipso facto lead to conclusion that it cannot be considered to be corpus contribution. It is true that in terms of section 12(1) read with section 11(1)(d) of the Act, what is not includible in the total income of a charitable institution is the receipt by way of corpus donation.

However the Act

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