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    Appellate enhancement cannot add a new source of income not examined in the original assessment.
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      Refund of part of CSR funds by a charitable trust to its donor...

      Charitable donation refunds need not defeat exemption where no donor benefit arises and funds remain applied charitably.

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      Income TaxJuly 20, 2026Case LawsAT
      Refund of part of CSR funds by a charitable trust to its donor is examined under the prohibition on applying income or property for the benefit of specified persons. The material states that charitable exemption was not denied because there was no evidence that the donor obtained a benefit from the refund, and the amount was immediately passed to another charitable organisation conducting rural education programmes. It presents the principle that a refund, without donor benefit and followed by charitable application through another organisation, need not constitute prohibited benefit to a specified person.

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      ActsIncome Tax