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2019 (2) TMI 1840 - ITAT BANGALOREExemption u/s 11 - assessee was granted registration u/s 12A - voluntary contributions received for a specific purpose - whether cannot be regarded as income u/s 2(24)(iia) since they are capital receipts to be utilised for specific purpose? - assessee has pleaded that the amount received by the assessee was a tied up grant or an amount received for a specific purpose as being capital in nature - HELD THAT:- Voluntary contributions received for a specific purpose cannot be regarded as income under section 2(24)(iia) of the Act since they are capital receipts to be utilised for specific purpose. Respectfully following the decision of ITO Vs. Vokkaligara Sangha [2015 (8) TMI 920 - ITAT BANGALORE] where we find the factual matrix therein to be similar to that of the case on hand and the decision therein squarely applicable to the instant case, we hold that the voluntary corpus donations / contributions received by the assessee in the periods under consideration (i.e., Assessment Years 2011-12 and 2012-13) for the specific purpose of purchase of lands for furtherance of the assessee’s objects cannot be regarded as income under section 2(24)(iia) of the Act since they are capital receipts for specific purpose. - Assessee’s appeals are allowed.
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