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    <title>2026 (5) TMI 1466 - ITAT PUNE</title>
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    <description>Voluntary contributions received by an unregistered religious trust were treated as corpus donations where donor lists, affidavits, receipts and audited accounts showed that the amounts were specifically earmarked for construction and renovation of the temple building. The record also showed that construction-related expenditure was incurred during the year, supporting the conclusion that the receipts were applied for the stated capital purpose. On that basis, the contributions retained the character of capital receipts and were not taxable as income. The addition was therefore deleted.</description>
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      <description>Voluntary contributions received by an unregistered religious trust were treated as corpus donations where donor lists, affidavits, receipts and audited accounts showed that the amounts were specifically earmarked for construction and renovation of the temple building. The record also showed that construction-related expenditure was incurred during the year, supporting the conclusion that the receipts were applied for the stated capital purpose. On that basis, the contributions retained the character of capital receipts and were not taxable as income. The addition was therefore deleted.</description>
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