ITAT confirms Section 11 exemption for Tata Social Welfare Trust: Investment in shares only accretion of bonus shares

The ITAT upheld Section 11 income-tax exemption for the Tata Social Welfare Trust, holding that bonus shares received as an accretion to existing investments do not constitute a fresh or speculative investment. The bench observed that such holdings were incidental to the trust’s charitable corpus and fully compliant with permissible investment norms under Section 11(5). It clarified that receipt of bonus shares does not violate charitable-trust investment conditions, thereby reinforcing the tax-exempt status of welfare trusts and strengthening jurisprudence around corpus-based income utilisation.