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6. Aggrieved by this order, assessee preferred appeal and consequently Ld. CIT(E) while referring to the explanatory memorandum to Finance Act, 2006, through which the Shree Samsthan Gokarn Parthagali Jeevotham Math, Mumbai provisions of section 115 BBC of the Act treating anonymous donations as income of the trust has held that in such explanatory memorandum, it was clearly mentioned that anonymous donation to wholly religious trust or institutions will not be taxed therefore allowed the appeal of the assessee.