Dismissing the appeal, that there was no evidence regarding specific direction given by the donor that the amount was given towards corpus fund of the assessee. It was nobody’s case that donors had collected any donation on behalf of the assessee from the students or from parents for giving the admission in the institutions run by the assessee. The Assessing Officer without looking into this issue, straightaway treated the donations as income of assessee. He had failed to carry out the necessary enquiry with regard to the sources from which the donors had donated the amount to the assessee. In the absence of such findings by the lower authorities, the order of the Commissioner (Appeals) could not be reversed. Relied   CHANDRAPRABHU Jain Swetamber Mandir v. ACIT (2016) 50 ITR (Trib)  355 (Mum), ITO(E) v. Smt. Basanti Devi and Shri Chakhan Lal Garg EEducation Trust (I. T. A. No. 5082/Delhi/2010 dated January 19, 2011), Indian Society of Anaesthesio Logists v. ITO (2014)  32 ITR (Trib)  152 (Chennai), ITO v. Gaudiya Granth Anuved Trust(2013) 28 ITR (Trib) 161 (Agra) and ITO v. Vokkaligara Sangha [2015 44 CCH 509 (Bang) (Trib). (AY.2015-16)