https://www.taxtmi.com/caselaws?id=771280 ITAT Mumbai held that donations received under 'Hundi Kanika' and 'Padapooja Kanika' by a trust qualified for corpus donation exemption under section 11(1)(d). The tribunal applied the rule of consistency, noting that the income tax department had consistently accepted this treatment in previous assessment years. The AO was not justified in treating these voluntary contributions from devotees as taxable income when the trust had consistently treated them as corpus donations and the department had previously accepted this position. The tribunal emphasized that fundamental aspects permeating through different assessment years should maintain consistency unless facts substantially differ. The assessee's appeal was allowed. en-us Mon, 28 Apr 2025 00:00:00 +0530 Fri, 23 May 2025 08:46:10 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=771280 ITAT Mumbai held that donations received under 'Hundi Kanika' and 'Padapooja Kanika' by a trust qualified for corpus donation exemption under section 11(1)(d). The tribunal applied the rule of consistency, noting that the income tax department had consistently accepted this treatment in previous assessment years. The AO was not justified in treating these voluntary contributions from devotees as taxable income when the trust had consistently treated them as corpus donations and the department had previously accepted this position. The tribunal emphasized that fundamental aspects permeating through different assessment years should maintain consistency unless facts substantially differ. The assessee's appeal was allowed. Case-Laws Income Tax Mon, 28 Apr 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=771280