The Appellate Tribunal has held that the contribution received by the assessee from co-operative societies towards specific purpose and the assessee has no discretion to spend the contribution received. The utilization of the contribution is to be decided by the Advisory Board consists of different persons as per the direction of the Government of Karnataka. The donations were for specific purposes which means that the assessee has agreed to act as a trustee for this contribution received from various co-operative societies. Thus, the donations received by the Assessee are for specific purposes and do not belong to the assessee. Hence, such donations do not form income of the assessee. ( AY. 2013-14 to 2015-16)
Karnataka State Co-operative federation Ltd. v. ACIT (2021) 186 ITD 750 (Bang) (Trib)
S. 4 :Charge of income-tax – Assessee a Federation of co-operative societies received contribution from its members towards co-operative education fund – Assessee had no discretion to spend amount received – the contribution could not be treated as income of assessee.[ S.80P(2)(a)(i)]