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3. The ld. Commissioner further noted that the assessee was collecting anonymous donations. The details submitted showed that Rs.6,42,800/- was collected in financial year 2006-07 for which receipts were issued without giving any name and address of donors. He was of the opinion that anonymous donations were treated as specific donations in spite of the fact the names and address of donors were not there on the receipts issued by the trust. Such donations were liable to be included in the total income and will be taxed at the rate of 30 per cent under section 115-BBC(1)(i) of the Act with effect from 1/04/2007. The ld. CIT further noted that the assessee trust had incurred an expense of Rs.2,40,167/- on Mandir Pooja during the year ended 31st March, 2008, which exceeded 5 per cent of the total income of the trust. Therefore, provisions of section 80-G(5) of the Act were not applicable to the facts of the case. He further noted that the trust was required to spend 85 per cent of income for claim of exemption under section 11 of the Act. In financial year 2005-06 the application of income was less than 85 per cent of the income even after giving the credit of Rs.13,08,978/- incurred towards fixed assets of the trust. He also noted that the balance sheets as on 31st March, 2006; 31st March, 2007 and 31st March, 2008 revealed that the trust had claimed to have received corpus donation at Rs.95,23,746/-, Rs.58,70,172/- and Rs.40,60,456/- respectively, but could not I. T. Appeal No. 4440 (Del) of 2009 produce even a single piece of paper as specific direction from the respective corpus donors as per section 11(1)(b) of the Act. He was, therefore, of the view that the trust had diverted the funds which should have been spent to the extent of 85 per cent for the welfare of the general public towards corpus. The assessee was asked to furnish the reply, but no such reply was given. The ld. Commissioner further noted that a locker for the trust was opened in Allahabad Bank, Brindavan in the name of three trustees. It means the modes of investment of funds of the trust were not transparent as per provisions of section 11(5) of the Act. He was of the view that the contents of locker were includible in the income of the trust and were taxable under section 13(1)(d)(i) of the Act which disqualified the trust for approval under section 80-G(5). The ld. CIT further noted that exemption or renewal of a trust is not automatic and has to be allowed only after looking into the facts and circumstances of each case. He placed reliance on the decision of Hon'ble Delhi High Court in the case of Kirti Chand Tarawati Charitable Trust Vs. DIT [Exemption] 232 ITR 11 (Del). He also placed reliance on the decision of Hon'ble Karnataka High Court in the case of Gajamnagappa & Sons Society Vs. Director of Income-tax (E) 269 ITR 59 (Kar.) wherein it has been held that grant of exemption was subject to the satisfaction of the authority with regard to the renewal. The ld. Commissioner accordingly was of the view that the trust was not entitled for renewal of exemption under section 80-G read with rule 11-AA of the I. T. Rules, 1962.