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    <title>2025 (2) TMI 574 - ITAT DELHI</title>
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    <description>ITAT Delhi held that life and institutional membership fees received by a trust are not voluntary contributions and therefore not eligible for exemption under section 11(1)(d). The tribunal ruled that regardless of whether these fees were specifically directed to form part of the corpus fund or their revenue/capital nature, they constitute income from property held under trust. The AO&#039;s addition of these fees to the assessee&#039;s income was upheld, with only 15% set-apart allowed. The appeal was dismissed following the precedent in CIT vs Divine Light Mission.</description>
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    <pubDate>Wed, 12 Feb 2025 00:00:00 +0530</pubDate>
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      <title>2025 (2) TMI 574 - ITAT DELHI</title>
      <link>https://www.taxtmi.com/caselaws?id=766028</link>
      <description>ITAT Delhi held that life and institutional membership fees received by a trust are not voluntary contributions and therefore not eligible for exemption under section 11(1)(d). The tribunal ruled that regardless of whether these fees were specifically directed to form part of the corpus fund or their revenue/capital nature, they constitute income from property held under trust. The AO&#039;s addition of these fees to the assessee&#039;s income was upheld, with only 15% set-apart allowed. The appeal was dismissed following the precedent in CIT vs Divine Light Mission.</description>
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      <pubDate>Wed, 12 Feb 2025 00:00:00 +0530</pubDate>
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