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4.2 During the appellate proceedings it was also submitted that the provisions of section 115 BBC of the Act were not violated by the appellant trust and the donations received from the nine donors cannot be categorized as anonymous donations. Section 115BBC reads as under:
"Anonymous donations to be taxed in certain case 115BBC. (1) Where the total income of an assessee, being a person in receipt of income on behalf of any university or other educational institution referred to in sub-clause (iiiad) or sub-clause (vi) or any hospital or other institution referred to in sub-clause (iiiae) or sub- clause (via) or any fund or institution referred to in sub-clause (iv) or any trust or institution referred to in sub-clause (v) of clause (23 C) of section 10 or any trust or institution referred to in section 11, includes any income by way of any anonymous donation, the income-tax payable shall be the aggregate of--