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TMI Blog2019 (5) TMI 779X X X X Extracts X X X X X X X X Extracts X X X X ..... under section 10(223)(vi) CCIT did not bring any material on record as to how assessee was doing any other activity in pursuance to aims and objects of assessee society. Merely because the assessee printed certain aims and objects as per the requirement of Registrar of Societies would not make out a case for rejection of the application of assessee for approval under the above provision. The material on record clearly suggest that assessee solely exist for educational purposes only. Merely because some other aims and objects have been mentioned other than education, which have also not been verified at this stage would clearly show that assessee is entitled for exemption / approval 10(23C)(vi) of the I.T. Act. The issue is covered ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ty. The Learned CCIT, therefore, concluded that assessee society is not solely operating for educational purposes. The explanation of assessee was called for. The assessee filed the submissions giving undertaking therein that assessee doing only educational work. However, aims and objects of the assessee society are the documents which State Government and Department of Registrar of Firms and Society provide for compulsory printing and assessee do the same otherwise the assessee society doing only educational work i.e., running school and college only, which is fully verifiable from the regular books of account and audited statements of accounts which were already placed on record. Not even a single work other than education was ever done b ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 5. We have considered the rival submissions and perused the material available on record. The Hon ble jurisdictional Punjab Haryana High court in the case of Harf Charitable Trust (Regd.) Malerkotla vs. Chief Commissioner of Income Tax And Another (supra) held as under : Held, allowing the petition, that the school run by the assessee as such was affiliated with the Central Board of Secondary Education and had also been granted registration under section 12A with effect from July 15,1997. Merely because one of the clauses of the trust deed provided that the trust would carry on other business as decided by the trustees that would not per se disentitle it from being considered for registration under section 10(23C)(vi) ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... nd without coming to any conclusion that the trust was carrying on any other activity under clause (i). It was also a matter of fact now that the trust had already also deleted the objectionable clause for the year 2010-11. The Chief Commissioner was directed to decide the assessee's application afresh. 5.1. It is not in dispute that the aims and objects of the assessee are to promote education and assessee in pursuance of aims and objects only carried out the educational activities. The assessee did not do any other activity, therefore, merely mentioning some other aims and objects would not disentitle the assessee for claiming exemption/approval under section 10(223)(vi) of the I.T. Act,. The Learned CCIT did not brin ..... X X X X Extracts X X X X X X X X Extracts X X X X
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