The Trust filed ‘Nil’ return claiming exemption u/s 11. The exemption claim u/s.11 was denied on the ground that the assessee was not registered u/s 12AA. Subsequently, the assessee filed application u/s. 154 claiming exemption u/s.10(23C)(iiiad) on the ground annual receipt is less than Rs. one crore. The AO, noted that the gross receipt is Rs. 1,21,82,696 (including corpus donation of Rs. 72,18,000) exceeding the prescribed limit of Rs. One crore and denied the exemption claimed u/s.10(23C)(iiiad). Further, rejected the application treating that there is no mistake apparent on record. The NFAC upheld the order passed by the AO. The Tribunal held that donation towards corpus would not form part of income of the assessee.  Thus, the assessee was entitled for exemption u/s.10(23C)(iiiad) and this would constitute mistake apparent from records.