In case of registered trusts : All kinds of receipts, whether capital or revenue nature are treated as income in the hands of a public trust or religious trust, except donations made with a written direction from the donor that the donation made shall be treated as part of the corpus of the trust. Such a donation to corpus shall not be included in the total income of a trust or institution. A donation is by its very nature a completed gift and once the donation has been accepted by the donee, the donor has no right to ask for the amount to be refunded. Donations to Corpus will also be similarly treated.
Interest earned on investment of Corpus Fund will be treated as income of a trust or institution. Such income if applied to charitable purposes, then it will be exempted from income tax.
Donors may make a contribution to Corpus Fund with certain stipulations and conditions, such as the purpose of the fund and its utilisation, and such conditions and stipulations will not in any way change the nature of the Corpus Fund i.e. it will still be exempt from income-tax.
In the present case we should check whether a Trust/institution can accept loan or not. Then if as per the provisions of income tax act, if the interest earned on the deposits are applied for charitable purpose then it is exempted. There is no tax implication when the amount is sent from abroad.