Corpus donations treated as revenue receipts may still qualify for exemption under Sections 11 and 12 for charitable trusts.

Corpus donations treated as revenue receipts were considered eligible for exemption and deduction under the charitable trust framework of Sections 11 and 12 of the Income-tax Act, 1961. The Tribunal accepted the assessee's alternative plea that, once the receipt was characterised as revenue in nature, it could be assessed under the exemption regime applicable to charitable trusts in accordance with law. On that premise, deduction under Sections 11 and 12 was held to be available.

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Issues: Whether corpus donations, once treated as revenue receipts, were eligible for deduction under Sections 11 and 12 of the Income-tax Act, 1961.

Analysis: The assessee's alternative plea was that if the corpus donation was assessed as a revenue receipt, the amount would fall to be governed by the exemption framework applicable to charitable trusts under Sections 11 and 12. The Tribunal accepted that once the receipt was treated as revenue in nature, the assessee could claim the benefit of those provisions in accordance with law.

Conclusion: The issue was decided in favour of the assessee, and deduction under Sections 11 and 12 was held to be available on the stated premise.

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