Anonymous donation tax provision held inapplicable to petty box collections received by a charitable trust.

Section 115BBC did not apply to small box collections and other petty offerings received by a religious and charitable trust in the ordinary course of its gaushala and animal-care activities. The provision targets anonymous donations used as a conduit for unaccounted money, whereas these receipts were found to be bona fide visitor offerings, with known donations separately identified and earlier departmental acceptance of the trust's activities supporting that characterisation. On those facts, the receipts could not be treated as anonymous donations, and the addition was deleted; the departmental appeal failed and the first appellate relief was sustained.

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Issues: Whether section 115BBC of the Income-tax Act, 1961 applied to small box collections and other donations received by the assessee trust, and whether such receipts could be taxed as anonymous donations.

Analysis: The statutory object of section 115BBC is to curb the routing of unaccounted money through anonymous donations. The receipts in question were petty offerings made by visitors in donation boxes and were associated with the trust's religious and charitable activities of maintaining gaushalas and caring for animals and birds. The trust had also identified and accounted for known donations, and its activities had been consistently accepted by the department in earlier years. On these facts, the collections could not be treated as the kind of anonymous donations targeted by the provision.

Conclusion: Section 115BBC was held to be inapplicable to the impugned receipts, and the addition made by the Assessing Officer was rightly deleted.

Final Conclusion: The departmental appeal failed, and the relief granted by the first appellate authority was sustained.

Ratio Decidendi: Section 115BBC is intended to tax anonymous donations used as a conduit for unaccounted money, not small bona fide offerings received by a religious or charitable trust in the ordinary course of carrying out its objects.

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