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Infrastructure grants expressly earmarked for stadium construction, credited to a corpus fund and applied for that purpose qualify as corpus donations exempt under section 11(1)(d). Accumulation under section 11(2) cannot be denied solely for delayed Form No. 10 filing where condonation was sought before assessment and subsequent relief applies. The statutory 15% accumulation under section 11(1)(a) is automatic and does not depend on Form No. 10. Additions made without a show-cause notice violate natural justice. A cricket association's activities do not attract the commercial-activity proviso absent evidence of trade, commerce or business. Depreciation, unspecified section 13 allegations and unsupported receipt enhancements require a factual and legal basis.
Infrastructure grants expressly earmarked for stadium construction, credited to a corpus fund and applied for that purpose qualify as corpus donations exempt under section 11(1)(d). Accumulation under section 11(2) cannot be denied solely for delayed Form No. 10 filing where condonation was sought before assessment and subsequent relief applies. The statutory 15% accumulation under section 11(1)(a) is automatic and does not depend on Form No. 10. Additions made without a show-cause notice violate natural justice. A cricket association's activities do not attract the commercial-activity proviso absent evidence of trade, commerce or business. Depreciation, unspecified section 13 allegations and unsupported receipt enhancements require a factual and legal basis.
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TaxTMI 
TaxTMI 
of 4897 
