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    <title>2022 (8) TMI 895 - ITAT DELHI</title>
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    <description>Development fee collected by an educational trust from students was treated as a corpus contribution where the fee structure, accounting treatment and application of the receipts showed a specific direction for capital purposes, even without a separate written direction; it was therefore not taxable as revenue income under section 11(1)(d). Accumulation under section 11(1)(a) was to be computed with reference to income derived from property held under trust, using the gross income base rather than net balance after expenditure. On both points, the additions were not sustained and the trust obtained the exemption benefit claimed.</description>
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      <link>https://www.taxtmi.com/caselaws?id=426656</link>
      <description>Development fee collected by an educational trust from students was treated as a corpus contribution where the fee structure, accounting treatment and application of the receipts showed a specific direction for capital purposes, even without a separate written direction; it was therefore not taxable as revenue income under section 11(1)(d). Accumulation under section 11(1)(a) was to be computed with reference to income derived from property held under trust, using the gross income base rather than net balance after expenditure. On both points, the additions were not sustained and the trust obtained the exemption benefit claimed.</description>
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