Compute total taxable income and tax liability of EHT for the assessment year 2025-26? (6 Marks)

Computation of total taxable income and tax liability of EHT for the A.Y. 2025-26 Income Amount (in lakhs) State Government Grant received for eye surgeries [See Note 3 below] 40 Voluntary contribution received 190 Net income from property held under trust 8 Corpus donations received where details are maintained [Assuming invested in the modes specified u/s 11(5)] Note – If it is assumed that corpus donation is not invested in the mode specified u/s 11(5), then the same would not be exempted. 238 Add: Anonymous donation [15lakhs +2 lakhs] [to the extent not chargeable to tax@30% under section 115BBC(1)(i)] [Refer Notes 1 & 2 below] 10.85 248.85 Less: 15% of income eligible for being set apart without any condition [Refer Note 2 below] 37.3275 211.5225 Less: Amounts applied for the objective of the trust 213 Total Income of the trust (before including anonymous donation) - Add: Anonymous donation taxable @30% under section 115BBC(1)(i) [See Note 2 below] 6.15 Total income of the trust (including anonymous donation taxable@30%) 6.15 Tax on anonymous donation @30% 1.845 Tax on balance income at slab rate - 1.845 Add: HEC @4% 0.0738 Tax liability 1.9188 Notes: (1) As per section 115BBC(1)(i), the anonymous donations in excess of the higher of the following would be subject to tax@30%; 10.85 lakh, being 5% of the total donations received i.e., 5% of 217lakhs [Voluntary contributions of 190lakhs (+) anonymous contributions of 17lakhs (+) Corpus donation of 10lakhs]; or 1 lakh Therefore, anonymous donations of 6.15 lakhs (17lakhs - 10.85 lakhs) would be subject to tax@30% under section 115BBC(1)(i). Such anonymous donations which are subject to tax@30 % are not eligible for the benefit of exclusion from total income under sections 11 and 12. (2) As per the plain reading of section 13(7), it appears that the entire anonymous donations may not be eligible for benefit of exclusion from total income under sections 11 and 12. If this view is taken, then - 10.85 lakhs should not be added to 238 lakhs for 15% unconditional exemption. Accordingly,35.7 lakhs, being 15% of 238lakhs would be the income eligible for accumulation without any condition. Computation of total income and tax liability would, accordingly, change. (3) Grants of 40lakhs received from State Govt. are not included in the total donations, in the above solution, while computing the limit of 5% of total donations u/s 115BBC(1). This view is taken since Govt. grants are generally given subject to stipulated conditions. However, in Income-tax Form ITR-7, Government grants are included in the total donations for the purpose of computing limit of 5% of total donations u/s 115BBC(1). Hence, the solution can also be worked out by including government grants in total donations for computing the limit of 5% of total donations.