DCIT (E) v. Indo Global Education Foundation. (2025) 212 ITD 341 (Chd) (Trib.)

S. 11 : Property held for charitable purposes-Education-Donation to other educational trusts-Application of income-Allowed exemption.[S.12A]

The assessee-trust, registered under section 12AA, was engaged in education and made donations to other educational trusts which were also registered u/s 12A. The AO denied exemption alleging diversion of funds and misuse. The Tribunal observed that once both donor and donee trusts are registered and the object of imparting education is fulfilled, the donation qualifies as application of income u/s 11. It further noted that in earlier scrutiny assessments such donations were accepted in the case of donee trusts. Hence, exemption could not be denied. Held, donations to other registered trusts for educational purposes amount to valid application of income.  (AY. 2012-13, 2014-15)