Corpus donation treatment depends on donor's specific direction and supporting evidence for trust income exclusion.

Voluntary contributions are excluded from a trust's income as corpus donations only when the donor gives a specific direction that the payment is for corpus. The character of the receipts depends on the evidence, including the donation receipts, and is therefore a question of fact. The matter was remanded to the Assessing Officer for fresh examination of the evidence and a determination of whether the donations were corpus fund receipts.

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Issues: Whether the voluntary contributions claimed as corpus donations were received with a specific direction so as to exclude them from the trust's income.

Analysis: Donations received towards corpus fund do not form part of the income of a trust only when the donor gives them with a specific direction that they are meant for the corpus. Whether the present receipts were corpus donations was a question of fact requiring examination of the evidence and the donation receipts.

Conclusion: The issue was remanded to the Assessing Officer for fresh examination of the evidence and for determining whether the donations constituted corpus fund receipts.

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