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TMI Blog2020 (2) TMI 546X X X X Extracts X X X X X X X X Extracts X X X X ..... the objection with regard to amassing capital fund and fixed assets. It was concluded that corpus created and the land and building was acquired out of donations, for setting up the school. Further, the point of fee receipt was also considered and it was held that the same was spent for running the school. The only issue raised by learned counsel for the Revenue needs to be considered is that the object to work for social, moral, intellectual upliftment of general public especially women brings the object of the assessee out of the phrase solely for educational purpose . The contention raised is not well founded. From the objects quoted above, it is forthcoming that the assessee was promoting quality education in the rural areas and m ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ave its activities 'solely for education', which is one of the main condition for granting approval u/s 10(23C)(vi)? II. Whether on the facts and circumstances of the case, the Hon'ble ITAT is right in not adjudicating the issue that despite assessee's receipts in excess of Rs. Two crores form F.U. 2013-14 onwards, applicant did not filed its return of income, which is necessary for the purpose of determination of genuineness of activities? III. Whether on the facts and circumstances of the case, the Hon'ble ITAT has erred in not adjudicating the issue that the assessee has filed application for grant of approval u/s 10(23C)(vi) for the first time on 17.10.2016, though the assessee has been claiming exemption ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... xemptions), Chandigarh [for short, 'CIT (E)'] while dealing with the application under Section 10(23C) of the Act considered the fact that there is denial of registration under Section 12AA of the Act. The application under Section 10(23C)(vi) of the Act was rejected vide order dated 31.10.2017. Appeal was preferred before the Tribunal, the same was allowed vide order dated 17.1.2019, hence the present appeal. Before proceeding further, the aims and objects of the assessee are reproduced as under: . . . to promote the quality and scope of education in Rural Area and manage the affairs of Sadhu Singh DAV, Rural Public School, Mukandpur; to work for social, Moral, intellectual upliftment of general public especially women; to pr ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ilding was acquired out of donations, for setting up the school. Further, the point of fee receipt was also considered and it was held that the same was spent for running the school. The only issue raised by learned counsel for the Revenue needs to be considered is that the object to work for social, moral, intellectual upliftment of general public especially women brings the object of the assessee out of the phrase solely for educational purpose . The contention raised is not well founded. From the objects quoted above, it is forthcoming that the assessee was promoting quality education in the rural areas and managing the affairs of Sadhu Singh DAV, Rural Public School, Mukandpur. The object for upliftment of general public especial ..... X X X X Extracts X X X X X X X X Extracts X X X X
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