https://www.taxtmi.com/caselaws?id=797473 Genuine voluntary contributions received with specific donor directions to form part of an educational institution's corpus retain their capital character and are not taxable merely because the institution claims exemption under Section 10(23C)(vi) rather than Section 11. Donor identity, banking-channel receipt, confirmation and an express corpus direction distinguish such receipts from ordinary voluntary contributions available for application toward institutional objects. The absence of an identically worded corpus exclusion under Section 10(23C)(vi) during the relevant year does not change the legal character of genuine corpus contributions; subsequent clarification under that provision supports this treatment. en-us Tue, 11 Aug 2026 00:00:00 +0530 Sat, 22 Aug 2026 10:33:33 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=797473 Genuine voluntary contributions received with specific donor directions to form part of an educational institution's corpus retain their capital character and are not taxable merely because the institution claims exemption under Section 10(23C)(vi) rather than Section 11. Donor identity, banking-channel receipt, confirmation and an express corpus direction distinguish such receipts from ordinary voluntary contributions available for application toward institutional objects. The absence of an identically worded corpus exclusion under Section 10(23C)(vi) during the relevant year does not change the legal character of genuine corpus contributions; subsequent clarification under that provision supports this treatment. Case-Laws Income Tax Tue, 11 Aug 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=797473