1985 (4) TMI 90

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..... y the appellant under s. 12 of the Act. The Departmental authorities had held that there was no specific direction letters from the donors that the donations shall form part of the corpus of the trust. Shri V.H. Patil, the ld. counsel for the appellant, pointed out that the donors were persons based in Singapore, and that in their letters they had specifically stated that the donations made by the .....

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..... e donations of Rs. 33,000 has been added to the trust fund or corpus to form part of the total fund or corpus of Rs. 1,13,000. He therefore, submitted that the conditions of s. 12 were satisfied and that the Departmental authorities were not justified in taxing the sum of Rs. 33,000 as income in the hands of the appellant. 2. On behalf of the Revenue, Shri Prem Kumar, the ld. Departmental Repre .....

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..... have kept these donations as part of the corpus of the trust of the trust fund, on the objects of the trust declared in the deed of trust. Clause 8 imposes an obligation on the trustees to hold such donations as part of the corpus of the trust and not fritter them away. So even if the letters of to the donors containing their specific directions at pp. 7 to 9 of the paper-book are to be eschewed f .....

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