CIT(E) v. Om Prakash Jindal Gramin Jan Kalyan Sansthan (2022) 444 ITR 498 /287 Taxman 303 (Delhi)(HC)

S. 11 : Property held for charitable purposes-Voluntary contributions towards corpus fund used for purchase of land-Allowable as application of income. [S. 11(1)((d)]

The Commissioner (Appeals) set aside the assessment order treating Rs. 19 crores as additional income of the assessee on the ground that exemption on corpus donation was allowable for purchase of land, as it was a purchase of capital asset. The Tribunal affirmed the order of the Commissioner (Appeals) allowing utilisation of corpus fund of Rs. 19 crores as application of income under section 11(1)(d) of the Income-tax Act, 1961. On appeal High Court affirmed the order of the Tribunal.  (AY.  2010-11)