Held that corpus donation with specific direction is a capital receipt and cannot be assessed as income of the assessee. Provision for gratuity, allowable as application of income. (AY. 2012-13)
Apeejay Education Trust v. DCIT (2021) 191 ITD 359 (Kol.)(Trib.)
S. 11 : Property held for charitable purposes-Donation received for Corpus fund with specific direction-Capital receipt-Not assessable as income-Provision for gratuity-Allowable as application of income. [S. 10(23C)(vi), 11(1)(d)]