Anonymous donation test under section 115BBC: names, addresses and confirmations prevented tax treatment as anonymous receipts.

Donations were held not to be anonymous donations under section 115BBC where the assessee maintained the donor's identity through names and addresses, supported by confirmation letters and banking-channel receipts. The absence of PAN in some confirmations did not, on the facts recorded, make the contributions anonymous because the statute requires maintenance of identity particulars, not additional mandatory details that were otherwise not shown to be essential. As the Revenue did not establish that the donations were ungenuine or that the statutory identity record was missing, the addition was deleted and the challenge to that deletion failed.

---

---

Issues: Whether the donations received by the assessee could be treated as anonymous donations taxable under section 115BBC of the Income-tax Act, 1961.

Analysis: Anonymous donation, for the purposes of section 115BBC, means a voluntary contribution in respect of which the recipient does not maintain a record of the donor's identity, including the name and address of the contributor and other prescribed particulars. The record showed that the assessee had furnished the names and addresses of the donors, supported by confirmation letters, and the donations were received through banking channels. The absence of PAN in some confirmations did not, by itself, make the receipts anonymous, as the statute requires maintenance of identity particulars and does not prescribe any further mandatory particulars on the facts found. The Revenue had not established that the donations were ungenuine or that the assessee had failed to maintain the statutory record of identity.

Conclusion: The receipts could not be classified as anonymous donations under section 115BBC, and the addition was rightly deleted.

Final Conclusion: The Revenue's challenge to the deletion of the addition failed, and the assessment as modified by the first appellate authority remained undisturbed.

Ratio Decidendi: A donation is not anonymous where the recipient maintains the donor's identity through the name and address of the contributor and the record is otherwise verifiable; absence of PAN alone does not attract section 115BBC.

---