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Corpus donations received by the trust for running Kalyana Mandapam were voluntary in nature and could not be treated as rental receipts. Although the activity generated surplus, the surplus was utilized for furthering other charitable purposes mentioned in the trust deed. The trust confined its activities within the boundaries set by the trust deed and did not drift from its objects. Therefore, the trust's claim for exemption u/s 11 could not be denied merely because the Kalyana Mandapam activity resulted in surplus funds. The Appellate Tribunal directed the Assessing Officer to grant exemption u/s 11 and recompute the income for all years.
Corpus donations received by the trust for running Kalyana Mandapam were voluntary in nature and could not be treated as rental receipts. Although the activity generated surplus, the surplus was utilized for furthering other charitable purposes mentioned in the trust deed. The trust confined its activities within the boundaries set by the trust deed and did not drift from its objects. Therefore, the trust's claim for exemption u/s 11 could not be denied merely because the Kalyana Mandapam activity resulted in surplus funds. The Appellate Tribunal directed the Assessing Officer to grant exemption u/s 11 and recompute the income for all years.
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