Rohilkhand Educational Charitable Trust v. DCIT (2025) 238 TTJ 173 / 178 taxmann.com 672 (Lucknow)(Trib.)

S. 12: Voluntary contributions-Trust or institution-Corpus Donations-Voluntary corpus donations cannot be denied merely because the trust requested donors to contribute towards the corpus. [S. 11, 132]

The Tribunal held that corpus donations retain their voluntary character merely because the assessee requested donors to contribute towards the corpus. In the absence of any evidence found during the search suggesting that the donations were not genuine, the Revenue was not justified in treating them as non-voluntary. However, in respect of five donors whose confirmations were not produced, the issue was restored to the Assessing Officer for verification, while the remaining additions were deleted. (AY. 2017-18, 2018-19)

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