1985 (4) TMI 90

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....ties were justified in denying exemption to the donations of Rs. 33,000 received by the appellant under s. 12 of the Act. The Departmental authorities had held that there was no specific direction letters from the donors that the donations shall form part of the corpus of the trust. Shri V.H. Patil, the ld. counsel for the appellant, pointed out that the donors were persons based in Singapore, and....

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....f the paper book as on 31st Dec., 1978. According to this balance-sheet, the entire donations of Rs. 33,000 has been added to the trust fund or corpus to form part of the total fund or corpus of Rs. 1,13,000. He therefore, submitted that the conditions of s. 12 were satisfied and that the Departmental authorities were not justified in taxing the sum of Rs. 33,000 as income in the hands of the appe....

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....and contained." In accordance with this clause in the trust deed, the trustees have kept these donations as part of the corpus of the trust of the trust fund, on the objects of the trust declared in the deed of trust. Clause 8 imposes an obligation on the trustees to hold such donations as part of the corpus of the trust and not fritter them away. So even if the letters of to the donors contain....