This case involves the Society for Welfare Awareness Research & Guidance, which contested the addition of Rs. 23,00,000 as corpus donation from Herbicure Bio-Herbal Research Foundation. The donation was scrutinized under the pretense of being an accommodation entry, leading to a significant legal battle over its legitimacy.
The case originated from a notice under section 148, due to information received suggesting the donation was an accommodation entry. Despite various legal submissions and evidence presented by the Society, both the AO and the ld. CIT(A) upheld the addition, leading to further appeals.
The Society challenged the addition based on the legitimacy of the donation received and its application towards charitable purposes. They argued that the donation, received through proper banking channels, was applied in accordance with the donor’s instructions, which should exempt it under the applicable tax provisions.
The Tribunal’s decision to delete the addition of Rs. 23,00,000 was based on the principles of justice and the evidence provided. This case highlights the challenges faced by non-profit organizations in proving the genuineness of large donations and the importance of maintaining thorough documentation and compliance with legal statutes.
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