ITAT upheld the AO's decision to treat one-time life membership ...

Life Membership and Institutional Fees Not Eligible for Section 11(1)(d) Tax Exemption as Non-Corpus Funds

February 15, 2025

Case Laws Income Tax AT

ITAT upheld the AO's decision to treat one-time life membership and institutional membership fees as non-corpus funds, making them ineligible for exemption under Section 11(1)(d). The Tribunal determined these fees were not voluntary contributions, rendering irrelevant whether they were specifically directed to form part of the corpus fund or their revenue/capital nature. The receipts were classified as income from property held under trust, with the AO permitting a 15% set-apart allowance. The appellant's challenge was dismissed, affirming that such membership fees must be included in the assessee's taxable income.

View Source

← Previous Next →

ITAT upheld the AO's decision to treat one-time life membership ...

Life Membership and Institutional Fees Not Eligible for Section 11(1)(d) Tax Exemption as Non-Corpus Funds

February 15, 2025

Case Laws Income Tax AT

You may also like:

Exemption u/s 11 - Life Membership Fees claimed as capital receipt of the corpus donation - by no stretch of imagination, membership fee can partake character of...

Corpus donations, being distinct from incomes derived from trust property, are granted exemption separately u/s 11(1)(a) and 11(1)(d) of the Act. There is no overlapping...

Tax Incentives to International Financial Services Centre - (i) Time limit for exemption on Transfer of assets of the original fund, or its wholly owned SPV to a...

Characterization of income - One time membership entrance fees as one time membership fees for life time membership of club (15 years) - membership fee received is...

Exemption u/s. 11(1)(d) - contributions received from students towards development and welfare funds of the school - voluntary contribution or otherwise - The ITAT...

The development fund received from students, apart from tuition fees, is treated as a capital receipt or corpus donation, not a revenue receipt. The fund is utilized for...

Education trust - corpus fund - AO was not justified in holding contributions towards different corpus funds as current income liable to tax. - AT

The Court held that the amount paid by parents for admission of students to the educational institution run by the trust should be treated as corpus donation and not...

The Income Tax Appellate Tribunal (ITAT) held that every non-compliance with a notice u/s 142(1) gives a separate cause of action for levying penalty u/s 271(1)(b)....

Levy of GST - supply of services or not - contribution made by Members towards “Annual Membership Fees and registration fees” to the Corpus Fund of BCSBI - The...

Disallowance of expenses u/s 37(1) by the CPC - Associateship fees paid to Mumbai Cricket Association - Membership of the employees of the company including Chairman and...

Corporate membership fees - revenue in nature or capital? - no reason why the renewal membership fees should not be allowed as revenue expenditure - HC

TDS (withholding tax) u/s 195 - Disallowance u/s 40(a)(i) - non-deduction of tax at source on payment made towards membership/subscription fee - principle of mutuality-...

Exemption 11 - utilization of corpus fund towards revenue expenditure as application of income under Section 11(1)(d) - exemption on corpus donation is allowed on...

Exemption u/s 11 - If the corpus has been received by the assessee for a designated purpose, the same should have utilized for that purpose only and if depreciation is...

Quick Updates: