Uncorroborated 132(4) Statement Can’t Tax a Genuine Donation

Nandlal Tolani Charitable Trust Vs ITO (Exemption) (ITAT Mumbai)

Assessee Trust made a donation of ₹10,00,000 to All India Social Educational Charitable Trust, a registered trust holding valid 12A & 80G approvals. AO treated the donation as bogus u/s 69C solely on the basis of search statements of two persons managing the donee trust, who allegedly admitted to returning donation amounts after retaining 0.25% commission. No seized material, no bank-trail, no corroborative documents, & no incriminating evidence against Asse

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