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Case law › Income-tax Act 2025 › Chapter XVII › Section 339
Chapter XVIIwas s.11

Section 339 of the Income-tax Act, 2025

Section 339 — Corpus donation. Successor to s.11 of the 1961 Act.

Where this section sits

Section 339 is in Chapter XVII — Special Provisions Relating to Certain Persons, which runs from section 302 to section 355.

← Section 338  ·  Section 340 →

What this section does

The section defines corpus donation: any donation made with a specific direction by the donor that it shall form part of the corpus of the registered non-profit organisation, provided that the donation is invested or deposited in one of the modes permitted under section 350, maintained specifically for such corpus.

Why it is there

A corpus donation is treated differently from an ordinary receipt of a non-profit organisation, so the Act has to say what qualifies. The definition attaches two conditions rather than one, so the character of the receipt depends on what the organisation does with the money and not only on what the donor writes.

Who it applies to

What this means in practice

Both elements must be present. A donor's direction alone does not make a corpus donation if the money is merged into general funds, and an investment in a permitted mode does not make one without the direction. The permitted mode must also be maintained specifically for the corpus, so corpus money held in the same account as other investments does not answer the definition. The direction must come from the donor and cannot be supplied afterwards by the organisation.

An example

Illustrative only, and invented for this page. The figures are chosen to show the rule biting, not taken from any real matter.

A donor gives Rs 50 lakh to a registered non-profit organisation with a written direction that it form part of the corpus, and the organisation places it in a mode permitted under section 350 in an account maintained specifically for the corpus. That is a corpus donation. The same Rs 50 lakh with the same direction, but credited to the general bank account and spent on running costs, is not.

Where you meet this section

In the accounts and return of a registered non-profit organisation, where corpus donations are shown separately from other receipts, and in the donor's written direction recorded when the donation is given — that direction and the corpus investment record are what the organisation produces when the treatment is questioned.

The words themselves

provided that such donation is invested or deposited in any of the modes permitted under section 350 maintained specifically for such corpus
Section 339, Income-tax Act, 2025.

What people get wrong

What this replaced

The correspondence is the Income Tax Department’s own, from its comparison utility for the 1961 and 2025 Acts. A renumbering is the easy half; whether the words changed is the half that decides cases.

See the full 1961 to 2025 concordance.

Circulars of the Board on this section

A circular binds the department, not you and not a court. Every one below was written under the 1961 Act; it reaches this section because the department’s own concordance carries the provision it names to this one.

See every circular and notification on this section, or the circulars index.

Notifications that reach this section

A notification is made under a power the Act gives and, within that power, is law. These too were made under the 1961 Act and are placed here by the department’s concordance. We hold 697 in all; the 250 most recent are listed.

See every circular and notification on this section, or the notifications index.

Case law carried across

Read this before you rely on it. Every decision below was decided under the Income-tax Act, 1961. It appears here because it is tagged to a 1961 provision that the department’s own mapping carries to section 339. That is an inference we have drawn, not a holding on the new section: where the words changed in the move, the reasoning may not survive. Treat this as the place to start looking, not as authority on the 2025 Act.

Explainers

Read with

What this page does not tell you. It does not reproduce the section. Everything above was written from the section’s own text as the Income Tax Department publishes it — the text is here, and nothing here is advice on your facts. Where a figure matters, read the sub-section it comes from.