Held that AO has allowed exemption under S. 11(1)(d) to the assessee-trust with respect to the corpus donation and loan amount despite his own finding in the assessment order that the corpus donation as well as the loan are voluntary contributions for the reason that the same were received from entities controlled by the same authority as the assessee. Revision order was affirmed with the direction that the voluntary contribution made with specific direction may be excluded.(AY. 2016-17, 2017-18)
Saifee Byjhani Upliftment Trust v. CIT (E) (2022) 216 DTR 23 / 220 TTJ 585 (Mum)(Trib)
S. 263 : Commissioner-Revision of orders prejudicial to revenue-Corpus donation and loan-Received from entities controlled by the same authority as the assesse-Voluntary contribution made with specific direction may be excluded-Revision was up held with direction. [S. 11(1)(d)]