Meenakshi Ammal Trust v .ACIT (2020)78 ITR 138 / 186 DTR 257/203 TTJ 785 (Chennai) (Trib)

S. 271(1)(c) : Penalty – Concealment – Failure to furnish details of persons from whom donations received — Not a case of concealment of income or furnishing inaccurate particulars of income — Penalty not leviable . [ S. 11, 132 ]

Tribunal held that the assessee had disclosed the entire receipt of donations. However the Assessing Officer found that it was not a voluntary donation but anonymous donation. When the assessee had disclosed the entire receipt and the expenditure and claimed the receipt was exempted under section 11 , merely because the assessee could not furnish the details of the persons from whom the donations were received, could not be a reason for concluding that the assessee had concealed any part of income or furnished inaccurate particulars. Making a statutory claim under section 11 could not be construed as furnishing inaccurate particulars.( AY.2011-12 to 2014-15)