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2023 (5) TMI 273 - AT - Income TaxAssessment of trust - anonymous donations made u/s 115BBC - assessee trust is a charitable organization registered u/s 12AA - HELD THAT:- We find that sub-Section (3) to Section 115BBC of the Act specifically defines an “anonymous donation” as any voluntary contribution referred to in sub-clause (iia) of clause (24) of section 2, where a person receiving such contribution does not maintain a record of the identity indicating the name and address of the person making such contribution and such other particulars as may be prescrible - no other particulars have been prescribed under this proviso. The assessee in the present case has duly complied with the requisites by maintaining the records of the donors in the form of their names and addresses thereby not making them anonymous donations and resultantly not attracting the rigours of the Section 115BBC - AO had conducted due verifications and enquiry at his end but has failed to point out anything constructive leading to the conclusion that the donations in question were anonymous. CIT(A) has passed a reasoned order after considering all the elements and ingredients involved in the present case and hence no reason to interfere with the observation and findings of the CIT(A) and uphold the same. Accordingly, the sole ground of appeal raised by the revenue is dismissed.
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