ITAT held that donations under 'Hundi Kanika' and 'Padapooja...

ITAT held that donations under 'Hundi Kanika' and 'Padapooja Kanika' are exempt corpus donations. The tribunal emphasized the principle of consistency in tax matters, noting that when fundamental aspects remain unchanged across assessment years and the tax authority previously accepted a specific treatment, it would be inappropriate to challenge the established position. The burden of proof lies with the assessee trust to substantiate specific donor directions. Given the consistent historical treatment and no substantial factual differences, the appellate tribunal upheld the assessee's grounds, ruling that the donations should not be treated as taxable income, thereby allowing the assessee's appeal and maintaining the exemption status.