https://www.taxtmi.com/caselaws?id=23037 A donation made with a specific direction that it form part of a religious trust's corpus is not income for levy of fee under section 70(1) of the Bihar Hindu Religious Trusts Act, 1950, because the charging provision applies to net income and not to the trust fund itself. Such a corpus-directed receipt is earmarked for a specific purpose and is outside ordinary income available for application. The same distinction is reflected in income-tax treatment of voluntary corpus contributions. Where doubt exists in a fiscal charging provision, construction must favour the assessee. On that basis, the corpus donation was not chargeable to fee and the levy was unsustainable. en-us Thu, 11 Feb 1988 00:00:00 +0530 Wed, 16 Dec 2009 12:18:21 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=23037 A donation made with a specific direction that it form part of a religious trust's corpus is not income for levy of fee under section 70(1) of the Bihar Hindu Religious Trusts Act, 1950, because the charging provision applies to net income and not to the trust fund itself. Such a corpus-directed receipt is earmarked for a specific purpose and is outside ordinary income available for application. The same distinction is reflected in income-tax treatment of voluntary corpus contributions. Where doubt exists in a fiscal charging provision, construction must favour the assessee. On that basis, the corpus donation was not chargeable to fee and the levy was unsustainable. Case-Laws Income Tax Thu, 11 Feb 1988 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=23037