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ITAT Jodhpur: Corpus Donations Not Taxable Under Section 10(23C)(vi) Claim

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Summary

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  • The ITAT Jodhpur has ruled in favor of Mewar University, allowing the appeal for AY 2017-18 and directing the deletion of ₹26,50,000 in corpus contributions from taxable income.
  • The Tribunal found that the contributions were specifically directed towards the corpus and should not be treated as ordinary revenue receipts merely due to the exemption claimed under section 10(23C)(vi).
  • It emphasized that the character of a receipt must be determined by its real purpose, not solely by the exemption provision invoked.
  • This decision clarifies the treatment of corpus donations and could influence future tax assessments for educational institutions claiming similar exemptions.

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