Voluntary contributions to a charitable trust remain taxable income without section 12AA registration, despite being labelled building fund receipts.

Voluntary contributions received by a charitable trust are treated as income under section 2(24)(iia) of the Income-tax Act, 1961. Where the trust is not registered under section 12AA, exemption under section 11 is unavailable, so the donations remain taxable. Characterising the receipts as building fund contributions does not change their tax treatment or exclude them from income.

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Issues: Whether voluntary contributions received towards building fund by a charitable trust without registration under section 12AA are taxable as income and ineligible for exemption under section 11.

Analysis: Voluntary contributions received by a trust created wholly or partly for charitable or religious purposes are included in income under section 2(24)(iia) of the Income-tax Act, 1961. In the absence of registration under section 12AA, exemption under section 11 is unavailable. The fact that the donations were stated to be towards a building fund did not alter their tax character.

Conclusion: The contributions were taxable income and could not be excluded on the plea that they were received for building fund purposes.

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