Tribunal held that   the objects of the assessee clearly established that it was providing education, medical relief and relief to the poor and no evidence was available on record to say that the assessee had been providing services in the nature of business. Therefore, the corpus donation was considered as a capital receipt irrespective of whether the institution enjoyed the benefit of section 11 or not.  The Tribunal also held that   the annual rent received by the assessee was far above the valuation in accordance with the Municipal Corporation of Delhi. For every three years there was an enhancement of rent received by the assessee in respect of both properties. The property had been let out to a charitable institution and even if the benefit was assumed, it was not derived by any individual but by another charitable institution. The Department had accepted all these years the agreement between the HNF and HLI without drawing any adverse view. No change of facts and circumstances had been brought on record and no independent evidence with a specific relation to the property in dispute was available on record. Therefore, the addition made by the Assessing Officer unsustainable. (AY. 2013-14)