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ITAT upheld the AO's decision to treat one-time life membership and institutional membership fees as non-corpus funds, making them ineligible for exemption under Section 11(1)(d). The Tribunal determined these fees were not voluntary contributions, rendering irrelevant whether they were specifically directed to form part of the corpus fund or their revenue/capital nature. The receipts were classified as income from property held under trust, with the AO permitting a 15% set-apart allowance. The appellant's challenge was dismissed, affirming that such membership fees must be included in the assessee's taxable income.
ITAT upheld the AO's decision to treat one-time life membership and institutional membership fees as non-corpus funds, making them ineligible for exemption under Section 11(1)(d). The Tribunal determined these fees were not voluntary contributions, rendering irrelevant whether they were specifically directed to form part of the corpus fund or their revenue/capital nature. The receipts were classified as income from property held under trust, with the AO permitting a 15% set-apart allowance. The appellant's challenge was dismissed, affirming that such membership fees must be included in the assessee's taxable income.
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