2014 (5) TMI 1031

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....The assessee is a society registered under the Societies Registration Act. The assessee-society is also registered under section 12AA of the Income- tax Act, 1961. The registrations are still in force. In the previous year relevant to the assessment year under appeal, the assessee has received the following specific funds :     Rs. (a) Amount received towards award fund 5,28,000 (b) Amount received towards IJA fund 13,32,000 (c) Amount received towards WSJA fund 2,45,184 (d) Life membership fees 22,38,587     43,43,771   4. In the computation of income filed by the assessee-society, the above- stated receipts have been treated as capital receipts forming part of the corpus fund of the assessee-s....

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....n the present appeal is examined in the above line of discussion, it is to be seen that life membership fee is definitely a corpus donation. The capital fund of a charitable society is built-up mainly by the life membership fee. This is more true in respect of associations like assessee. The assessee is a society of practising anaesthesiologists. Therefore, among other items, the life membership fee contributed by the members is also capital fund of the society. There should not be any doubt that the life membership fee always remains as contribution to the corpus fund of the society. The amount received by the society towards award fund is a specific fund. The contribution received to that specific fund is accumulated as capital fund in th....