J Education Centre, a Charitable trust registered u/s 12AB of Income-tax Act runs schools for primary and secondary education. The following…

(i) Computation of total income of J Education Centre, a Charitable Trust for the A.Y.2025-26 Particulars ₹ Gross Receipts from students 1,75,00,000 Interest from tax-free bonds specified in section 10(15) [not eligible for exemption, since trust is registered u/s 12AB] 20,00,000 Voluntary Contribution [other than anonymous donations] 9,00,000 Grant from the State Government - 8.50 lakhs [Corpus Fund] [Assuming invested in the modes specified u/s 11(5)] Note If it is assumed that grant from State Government, being corpus fund is not invested in the mode specified u/s 11(5), then the same would not be exempted. Nil Anonymous donations [to the extent not chargeable to tax@30% under section 115BBC(1)(i)] being 1lakh, is to be considered here. The balance of 50,000 of anonymous donation is taxable @30% under section 115BBC. Note: Total donations - 10.50 lakh includes anonymous donation of 1,50,000. (i) 5% total donation being - 52,500; (or - 95,000 if Government grants are considered) (ii) Monetary limit - 1,00,000, whichever is higher is not taxable under section 115BBC. So, the balance of 50,000 taxable @30% under section 115BBC. The sum of 1,00,000 is considered for computing aggregate receipts to reckon 15% and consequently the total income of the trust. Alternatively,1,00,000 can be considered only for inclusion in total income and not for computing 15%. The consequence of this is given as note at the end of the answer to this question. 1,00,000 Capital gains on transfer of land [₹ 10.50 lakhs -5,00,000] 5,50,000 2,10,50,000 Less: 15% of income eligible for being set apart without any condition 31,57,500 1,78,92,500 Less: Amounts applied for charitable purposes Salary to teachers and administrative staff [Salary expenses of 5lakhs not paid during the P.Y. 2024-25 not treated as application] 35,00,000 Other General Expenses [Payment of 60,000 made through uncrossed cheque not treated as application] 19,40,000 Capital gains of 5.50 lakhs [₹ 10.50 lakhs -5 lakhs] arising on transfer of land treated as application of income since entire consideration is utilised for acquiring another land for the purpose of trust 5,50,000 Amount utilised in excess of net sales consideration for acquisition of land would also be treated as application [₹ 12,00,000 - 10,50,000] 1,50,000 61,40,000 Income of the trust (before including anonymous donation) 1,17,52,500 Add: Anonymous donation taxable under section 115BBC 50,000 Total income of the trust 1,18,02,500 Note - As per the plain reading of section 13(7), it is possible to take a view that the anonymous donations of 1lakh exempt from section 115BBC is not eligible for 15% accumulations. In such case, the amount eligible for 15% accumulations would be - 209.50 lakhs. 15% thereon would be - 31.425 lakhs. The total income computation sequence would be - 209.50 lakhs less 15% thereon being - 31.425 lakhs = 178.075 lakhs. Deducting - 61.40 lakhs = 116.675 lakhs. Adding anonymous donation (not taxable u/s 115BBC) 1lakhs = 117.675 lakhs. Adding - 50,000 taxable u/s 115BBC the total income would be - 118.175 lakhs.