ITA No.2386/Chny/2025

Parties Involved

Facts Summary

The assessee, ICICI Foundation for Inclusive Growth, is a charitable trust registered under section 12AA and approved under section 80G of the Income Tax Act, 1961. During the assessment year 2012-13, the assessee received corpus donations totaling Rs.26,10,59,858/- from various entities. The Assessing Officer accepted these donations as corpus donations and exempt under section 11(1)(d) of the Act. However, the Assessing Officer treated the withdrawal of Rs.19,34,72,836/- from the corpus fund as income, citing increased administrative expenses. Additionally, the Assessing Officer disallowed 50% of the administrative expenses amounting to Rs.5,30,70,160/-, alleging excessive expenditure. The Ld. Commissioner of Income Tax (Appeals) deleted both the addition and the disallowance, holding that the corpus donations were utilized in accordance with the trust deed and that the administrative expenses were incurred for charitable purposes.…

Legal Issues

• 1. Whether the withdrawal from the corpus fund should be treated as income of the assessee.
• 2. Whether the disallowance of administrative expenses was justified.

Judgment Outcome

Decided in favour of Revenue.

Precedents Relied Upon

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