2025 (11) TMI 1397

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.... by National Faceless Assessment Centre, Delhi u/s.143(3) r.w.s. 144B of the Income-tax Act, 1961 (hereinafter referred to as the "Act"), dated 31.06.2021 for AY 2018-19. 2. The only issue involved in the present appeal is in respect of treatment of corpus fund donation of Rs. 1,74,01,475/- received by the assessee during the year as income chargeable to tax without considering the provisions of section 11(1)(d) of the Act. 3. Brief facts of the case are that assessee was incorporated on 22.04.2017 vide its registered trust deed placed on record. Assessee is registered u/s.12AA/12A, vide registration number E-49792 (Mumbai) dated 03.10.2017. Assessee is also registered with the Charity Commissioner, Mumbai vide registration No. E-3330....

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....d that assessee has furnished copies of 76 letters vide which it has received the said corpus fund donations from 76 persons. In the same paragraph, on the observation of the ld. AO that assessee has not incurred any expense on account of any charitable/religious/educational activities, he noted that, assessee made a submission contending that it has not incurred any expense on charitable activities out of the corpus fund received by it. In this respect, it was submitted that assessee had earned income of Rs 1,24,341/- from investment of trust corpus fund and voluntary donations, out of which a sum of Rs 28,430/- was spent on the objects of the trust for which all the required details were furnished and for the balance amount, return of inc....

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.... iii. Bank Balance - Rs 58,97,38/-. 4.1. Thus, the entire corpus fund donation received during the year was invested in the above stated manner. It was further stated that assessee purchased two premises for carrying out objects of the Trust in the assessment year 2019-20, details of which is noted as below: i. Flat No. 106, B Wing, Atlantis, Heera Nandani Garden, Powai, Mumbai 400076, purchased for Rs 2,65,00,000/- on 23.04.2018 plus the stamp duty and registration charges, which totaled up to Rs 2,72,82,000/-. ii. Flat No. 104, A Wing, Heera Nandani Garden, Powai, Mumbai 40076 which was also purchased for the same amount of Rs 2,72,82,000/-. Copies of registered purchased deed for these two properties are placed on....

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....by the assessee before the authorities below. All the necessary details in respect of corpus fund donation received by the assessee and its subsequent utilization are placed on record, which are verifiable. It is pertinent to note that registration u/s. 12AA, Section 80G and with Charity Commissioners, Mumbai is valid as on date, which proves that assessee is engaged in charitable activities and the corpus fund donation received by it has been utilized for purchase of the immovable properties for carrying out object of the trust. 5.1. Ld. CIT(A) has dismissed the appeal despite taking note of all the factual submissions made by the assessee by holding that assessee has not submitted documentary evidences to substantiate its claim, which ....