ITAT denied exemption under sections 11 and 12 for voluntary...

ITAT denied exemption under sections 11 and 12 for voluntary contributions received by the assessee. The tribunal found no evidence demonstrating that donations were specifically directed toward corpus formation as required under section 11(1)(d). Per section 12, voluntary contributions without specific corpus designation must be treated as income of charitable trusts. Additionally, the assessee failed to satisfy the prerequisite condition of registration or application filing under section 12AA, which is necessary for exemption eligibility under sections 11 and 12A. The tribunal determined that "Income" under section 2(24)(iia) would remain part of total income absent proper registration. Accordingly, the assessee's appeal was dismissed.