Sec 12 a

Sir,

A Trust applied for Registration u/s 12 A of the I.T. Act. The same was rejected by the CIT and the case was reopened. Whereas the Trust has  already taken Donation in the Form of CORPUS FUND for its objects . Now the A.O. is treating the same as Income of the previous year and taxing the same.

Query:

1. Whether the A.O. can do the same?
2. Whether A.O. can Treat the CORPUS FUND as income of the Trust?
3. If not please provide some case laws.