Held, dismissing the appeal, that though the amount received from the donor SHGPH was initially claimed as donation towards corpus by the assessee, subsequently, it was admitted by the assessee to be general donation. The Department had not disputed that the amount so received by the assessee was general donation which was subjected to tax as per the order of the Settlement Commission under section 245C. The Commissioner (E) had not recorded any finding disbelieving the application of fund by the assessee towards its objects. The details of application of fund and receipt of donations were furnished by the assessee, which had been reproduced by the Tribunal in its order. The alleged brokers were not examined by the Department so as to disbelieve the donations received by the assessee. Instead, the donations received by the assessee were treated as general donations and accordingly it was subjected to tax in the hands of the assessee. The findings recorded by the Tribunal were findings of fact based on consideration of relevant evidence on record. Therefore, there was no illegality or perversity in the order of the Tribunal setting aside the order of the Commissioner (E) cancelling registration of the assessee-trust under section 12A of the Act.(AY. 2013-14)