Donor-directed corpus contributions retain capital character despite exemption claims under section 10(23C)(vi), preventing their treatment as taxable revenue.

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....Donor-directed corpus contributions received by an approved educational institution retain their corpus character where donors specifically earmark them, even when exemption is claimed under section 10(23C)(vi) rather than section 11. Such contributions are materially distinct from ordinary voluntary receipts available for application towards institutional objects. The absence of identically worded corpus provisions in section 10(23C)(vi) during the relevant year does not by itself recharacterise genuine corpus receipts as taxable revenue, absent material showing that the corpus designation is a facade. Accordingly, the addition for these corpus contributions was deleted.....