ITA 6850/DEL/2025

Parties Involved

Facts Summary

The assessee, a charitable trust running educational institutions, collected a Development Fund of Rs. 13,32,42,321/- from students. The Assessing Officer (AO) categorized this fund as revenue receipt, but the Commissioner of Income-tax (Appeals)-3 (CIT(A)) held it as a corpus receipt under section 11(1)(d) of the Income Tax Act, 1961. The Revenue appealed against this decision. The Tribunal upheld the CIT(A)'s decision, finding no reason to interfere with the findings.…

Legal Issues

• 1. Whether the CIT(A) erred in treating the Development Fund as a corpus donation.

Judgment Outcome

Decided in favour of Revenue.

Precedents Relied Upon

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