For a contribution to be a 'Voluntary contribution' and to avail exemption u/s 11(1)(d), identity of donors need to be established

To avail exemption under section 11(1)(d) in respect of Voluntary contributions made with a specific direction that they shall form part of the corpus of the trust/institution, identity of donor(s) must be established. If identity of donors not established, there is no question of the donations having been received with such a direction - ITO v. SMT. VIDYAWANTI LABHURAM FOUNDATION FOR SCIENCE RESEARCH & SOCIAL WELFARE [2012] 20