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TMI Blog2023 (9) TMI 897X X X X Extracts X X X X X X X X Extracts X X X X ..... s the other purposes of the trust in running other activities is concerned, it was found that though it was the sole object of the institution to provide education, the ancillary activities such as promotion of cultural and social activities were co-related to the main activity of education. Perusal of the order of the Tribunal would indicate that the Tribunal found that the fees received from the students and transportation etc. were for reimbursing expenses for such purposes. The Profit and Loss account of the trust also clearly established that the trust is engaged in the educational activities and the nominal profit that it earned was not a ground on which the CIT(E) would have disregarded the application. Having perused the order ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e written submissions filed by the trustee, the CIT(E) rejected the contentions of the assessee. On examination of records and the trust deed and the objects of the society together with the Profit and Loss Accounts, the CIT(E) found that it cannot be said that the trust was predominantly engaged in carrying educational activities. 4. On an appeal, the Tribunal in paras 13 to 16 observed as under: 13. We have heard both the parties and carefully gone through the submission put forth on behalf of the assessee along with the documents furnished and the case laws relied upon, and perused the fact of the case including the findings of the ld. CIT(Exemption) and other materials brought on record. Before us, the Ld. Counsel has submitted ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... vior among the students, the other activities, such as sports, social and cultural etc. are carried out by the assessee-Trust. 15. The ld Counsel submitted before the Bench the acknowledge copy of return of income along with computation of total income for assessment year 2018-19 which is placed at paper book page no.12. The audit report for AY.2019- 20 is submitted, which is placed at paper book page no.14. The copy of profit and loss account and balance sheet for AY.2018-19 is submitted, which is placed at paper book page nos. 17 to 18. The trust deed of the assessee trust is placed at paper book page no.19. The assessee also submitted the Certificate of Registration with Charity Commissioner. which is placed at paper book page no.2 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... and social activities were co-related to the main activity of education. 6. Perusal of the order of the Tribunal would indicate that the Tribunal found that the fees received from the students and transportation etc. were for reimbursing expenses for such purposes. The Profit and Loss account of the trust also clearly established that the trust is engaged in the educational activities and the nominal profit that it earned was not a ground on which the CIT(E) would have disregarded the application. 7. Having perused the order of the Tribunal, we find no reason to interfere. No substantial question of law is involved for consideration of this court, as based on facts and the appreciation of the trust deed, the Tribunal has rightly found ..... X X X X Extracts X X X X X X X X Extracts X X X X
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