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ppellant got registered under s. 12AA of the Act and as the donations/voluntary contributions received of Rs. 3,33,11,930 by the appellant society are of Corpus and Capital nature, same are to be treated as exempt from tax liability, as the principles relating to judicial discipline assume significance and the priority. Accordingly, following the ratios of the judicial pronouncements mentioned supra, it is treated that the donations/voluntary contributions received by the appellant society are outside the taxations, even for the period prior to its registration under s. 12AA. Hence, the AO is directed to delete the disallowance/addition made of Rs. 3,33,11,930 in this regard."

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Sec. 12AA,& 11(1)(d) of Income-tax Act, 1961— Charitable Trust— Corpus specific voluntary contribution being in nature of capital receipt, are outside scope o income under s. 2(24)(iia) and, thus same cannot be brought to tax even in case of trust not registered under ss. 12A/12AA- donations/voluntary contributions received by the appellant society are outside the taxations, even for the period prior to its registration under s. 12AA- - ITO V/s HOSANNA MINISTRIES - [2020] 185 ITD 144 (ITAT-VISAKHAPATNAM)

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