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Corpus donations were held exempt under section 11(1)(d) because the decisive factor is the donor's specific direction, not whether the trust deed separately authorises acceptance of such contributions. The donor letters described the receipts as corpus donations, and the Revenue did not dispute their genuineness or show diversion from the trust's objects. The Tribunal also applied consistency, noting that similar receipts had been accepted in later years on the same facts. As corpus receipts were excluded from income, the alleged shortfall in application of income could not survive; in any event, Form No. 9A had been filed before completion of assessment, supporting accumulation relief.
Corpus donations were held exempt under section 11(1)(d) because the decisive factor is the donor's specific direction, not whether the trust deed separately authorises acceptance of such contributions. The donor letters described the receipts as corpus donations, and the Revenue did not dispute their genuineness or show diversion from the trust's objects. The Tribunal also applied consistency, noting that similar receipts had been accepted in later years on the same facts. As corpus receipts were excluded from income, the alleged shortfall in application of income could not survive; in any event, Form No. 9A had been filed before completion of assessment, supporting accumulation relief.
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