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Issue ID: 121131
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Corpus donation - Anonymous treatment

Date 20 Sep 2026
Replies 1 Reply
Views 352 Views
Anonymous donations require donor identity records despite banking trails, while corpus status depends on a specific donor direction.
Corpus-donation treatment requires a donor's specific direction that the contribution form part of the corpus; a specified-purpose restriction or accounting classification alone may not suffice. Contributions lacking donor identity records may be treated as anonymous donations under section 115BBC despite a banking trail. Bank and payment records should be examined to reconstruct donor identity. Form 10BD non-filing does not itself determine anonymous-donation status. Unidentified receipts should be appropriately disclosed in Form 10B and ITR-7 with related tax implications considered. (AI Summary)

Respected Sir

Charitable Trust, registered u/s.12A of the Income tax Act, 1961. During the year 2025-26, the Charitable Trust has received total 2,00,00,000/- contribution for specific purpose, which has been credited in Bank through NEFT/RTGS/UPI. Therefore, in Books of Accounts, we consider the same as Corpus Donation and showing in Balance sheet. Out of the total contribution of Rs.90,00,000 donors name are not known. Hence, we could not file Donation statement in Form 10BD for the FY 2025-26. In this connection, do we consider such Rs.90,00,000 contribution as Anonymous contribution in filing Audit Report Form 10B/10BB as well as in Return of Income filing..

Please guide me

Income Tax
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Replied on Oct 1, 2026
1.

For FY 2025-26, first establish whether the Rs. 2 crore is genuinely corpus donation under section 11(1)(d). A mere "specific purpose" restriction does not necessarily constitute a donor's specific direction to form part of corpus.

For the Rs. 90 lakh where donor names are unavailable:

  • NEFT/RTGS/UPI proves the banking trail, but does not by itself establish donor identity.
  • Check bank statements, UTR/remitter details and payment records to reconstruct donor identity.
  • If the trust genuinely cannot maintain the prescribed donor identity records, the Rs. 90 lakh should be considered for section 115BBC (anonymous donation).
  • Do not assume that calling it "corpus" in the books automatically excludes it from section 115BBC; this area has litigation risk.
  • Form 10BD is a separate 80G reporting requirement and its non-filing does not itself determine whether the receipt is anonymous under section 115BBC.
  • If ultimately anonymous, the amount should be appropriately disclosed in Form 10B and ITR-7, with section 115BBC tax implications considered.

Recommended approach: Before finalising Form 10B/ITR-7, make documented efforts to obtain donor identity from bank/payment records and retain evidence of those efforts. Treating Rs. 90 lakh as exempt corpus without donor identification/supporting corpus direction carries litigation risk.
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