- (1.) These are the four appeals filed by the assessee against the common order dated 29-6-93 passed by the Deputy Commissioner (Appeals) for the assessment years 1980-81, 1981-82, 1982-83 and 1983-84 respectively. All the four appeals have the identical issues and, therefore, for the sake of convenience, they are disposed of by this consolidated order.
(2.) The brief facts of the case are that the assessee is a religious institution and receiving donations /voluntary contributions from the devotees. For this purpose, the assessee kept two Goloks (Boxes); one for 'corpus donation' and another for 'non-Corpus donation' in the premises of the temple.
(3.) The main grievance of the assessee is that the authorities below have not allowed "corpus" donation received from the different donors. The original assessments were challenged by the department before theTribunal who allowed the appeal for statistical purposes and set aside the assessments for determination by the assessing officer. The assessing officer after issuing a fresh notice, enquired and verified, observed that the Trust in the temple premises maintained two Goloks (Boxes); one marked "Corpus Donations" and other marked as' Donation". He observed that the donations credited in the Balance Sheet for received "Corpus" donation cannot be treated as such and is not exempted under section 12 and the same income was included with the 'total income".;