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11. That the Commissioner of Income-tax (Appeals) erred on facts and in law in holding that the appellant received anonymous donations aggregating to Rs.13,68,99,745 covered under section 115-BBC of the Act.

12. That the Commissioner of Income-tax (Appeals) erred on facts and in law in upholding the addition of Rs.6,52,493, being the value of Tata Sumo (vehicle) received as donation by the appellant.

13. That the Commissioner of Income-tax (Appeals) erred on facts and in law in holding that construction of building on land not owned/ registered in the name of the appellant could not be regarded as application of income for charitable purposes.