that
assessee has received Rs. 22,76,539/- on account of corpus fund and revenue receipts
of Rs. 96,36,555/-. The Assessing Officer therefore ... lacs from Shri
Chaganlal Sharma, the founder member against the corpus fund for meeting out the
capital expenditure. The Assessing Officer wrongly taken donation
respect of individual members of the society whose
membership fund/associate membership fund disclosed as
corpus fund; by invoking provisions of section ... fund, in the garb of donation, is actually some
unexplained/unaccounted fund; which part is, then required to
be added back as unexplained/unaccounted fund
Akhand Deepak fund - Rs. 12,951/-
6. Dadawadi fund - Rs. 25,020/-
7. Jiv Daya fund - Rs. 18,063/-
8. Ayambil fund ... that specific funds created for
fulfilling specific objectives for which these separate funds
are constituted remain as capital funds as the funds can be
used
assessee had made withdrawal of Rs.17,00,000/- from the corpus
fund of SDRR Public School. The liability side of the balance sheet ... From the perusal of sanction of the amount withdrawn from the corpus fund
of Sarti Devi Raja Ram Public School (hereinafter 'the school
word "corpus" is
not mentioned in letter specifically.
4.2. Ld.AR further submitted that taxability of contributions
towards 'corpus fund ... funds to
be towards 'corpus'. Further assessee has been able to prove
that corpus fund was received for meeting out capital
expenditure which
corpus fund lying with the company to total
investible funds, as the beginning of the year. It was strongly
contended that the corpus fund held ... which has been bifurcated to the policyholder fund, shareholder
fund and corpus fund in the ratio of balances at the beginning of
the year
Assessing Officer on account of income earned on
investment of corpus fund."
I.T.As. No.366 & 367/DEL/2018 ... been
earning income of Rs.875.13 lac from investing in corpus
funds which was not credited in the P&L account. In
response
page 10 of the Paper Book which talked of the corpus funds under which Rs.90
Lakhs was transferred under income & expenditure account then ... from surplus to corpus fund, clean air and vehicular emission
fund, road safety and traffic management fund and automotive fund. The
questions which needs
that in the first Balance Sheet dated
22.6.2009 there was no corpus fund and during search no corpus donation
was stated to have been received ... stated that corpus donation represent acquisition
of assets (land, building and others) on behalf of the trust by the trustees. Corpus
funds is also seen
Appellant on the premises that the transfer from the corpus Fund to
General Reserve tantamount income of the assessee and the same was not
offered ... found no substance on the
action of the AO because the Corpus Fund was utilized for purchase of
land i.e. Capital Assets. The Income
