CIT .v. Shri Jain Shwetamber Nakoda Parshwanth Tirth (2022) 211 DTR 310 / 325 CTR 550 (Raj) (HC)

S. 11 : Property held for charitable purposes – Corpus donation – When the Assessee-trust has received donations for specific purposes with specific directions by donors alongwith signatures of such donors, then such receipts are to be treated towards corpus donations. [ S. 12 ]

Dismissing the appeal of the Revenue, the High Court held that it can be seen that the CIT(A) and the Tribunal after detailed examinations had come to the conclusion that the Assessee-trust was maintaining separate receipts for corpus donations and for the donations received for general purposes. The receipts maintained for corpus donations shows the directions issued by the donors for the use of the fund for specific purposes. Such receipts also contain signatures of the donors.  It was therefore concluded that such donations cannot be said to be not used for specific directions of the donor towards corpus funds and accordingly such corpus donations cannot be treated as revenue receipts.  In view of such facts, we find no error in the views of CIT (Appeals) and Tribunal. No question of law arises..  (AY 2016-17)