Corpus donation for community hall construction treated as capital receipt, with taxability not turning on section 12AA registration.

Voluntary contributions collected through a donation box for construction of a community hall were treated as corpus donations on the facts stated, because the receipts were used for capital expenditure and were not shown to arise from any specific written direction of donors. The Tribunal noted that corpus donation is a capital receipt and held that its taxability did not depend on registration under section 12AA for the relevant year. The receipt was therefore treated as not liable to tax, and the corresponding disallowance was deleted.

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Issues: Whether voluntary contributions received for construction of a community hall could be treated as corpus donation and, if so, whether such receipt was taxable merely because the trust did not have registration under section 12AA for the relevant assessment year.

Analysis: The contribution was found to have been collected from devotees through a donation box and not through any specific written direction of donors. The amount was used for construction of a community hall, which was treated as capital expenditure. The Tribunal held that corpus donation is a capital receipt and, on the facts of the case, its taxability did not depend upon registration under section 12AA for the relevant year.

Conclusion: The receipt of Rs. 88,20,088/- was held to be a capital receipt not liable to tax, and the disallowance was deleted.

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