Corpus donations supported by remand report cannot be treated as unexplained income against the assessee.

Where donations are shown, on the Assessing Officer's remand report, to have been received from the donors with specific instructions that they form part of the society's corpus, the addition cannot be sustained as unexplained income. The appellate relief was upheld because the Revenue failed to show any valid basis to disturb the finding that the receipts were corpus contributions supported by the remand material. The legal principle stated is that an addition treating such donations as unexplained income cannot stand where the departmental remand report itself supports the assessee's explanation.

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Issues: Whether the Revenue could succeed in challenging the deletion of addition made by treating donations as unexplained income.

Analysis: The lower appellate authority relied on the Assessing Officer's favourable remand report, which ed that the donations had been received from the concerned donors with specific instructions that they would form part of the society's corpus. In view of that remand finding, the Revenue could not establish a valid basis to disturb the appellate relief.

Conclusion: The issue was decided against the Revenue and in favour of the assessee.

Ratio Decidendi: Where the Assessing Officer's remand report supports the assessee's explanation that donations were received as corpus contributions from the donors, the Revenue cannot be treated as an aggrieved party and the addition as unexplained income cannot be sustained.

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