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2018 (8) TMI 57 - AT - Income TaxEntitlement to benefit of section 11(1)(a) & 1l(l)(d) and u/s 12 - addition on ground that the assessee is pursuing its object of imparting and spreading education with profit motive and not that of charity purpose - Held that:- Since in the instant case the registration granted under Section 12A is still in force and since the object of the assessee society has not under gone any change, therefore, considering the totality of the facts of the case, we deem it proper to restore the issue to the file of the Assessing officer with the direction to adjudicate the issue a fresh in light of the decision of Adarsh Public School cited (2018 (2) TMI 1692 - ITAT DELHI)wherein held that the assessee’s income by way of fees cannot be held to be derived from property held under the trust because students cannot be treated as property - decided in favour of assessee for statistical purpose.
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