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2020 (5) TMI 371 - AT - Income TaxExemption u/s.11 - registration u/s.12A cancelled - allegatin that, assessee charges fees to students as per its prospectus but no charitable work is carried out as students are enrolled with full fees and other expenses which they have to incur. - assessee has set apart 15% of the amount to be carried forward to subsequent years - HELD THAT:- In the case of the assessee, students who get admission pay the development fee and without the same, there would be no admission for them. There is an element of quid pro quo for them and therefore, the students are exactly aware for what purpose their fee is going to be used for. For a moment, even if it is held that development fee is revenue receipts, the same are still eligible for deduction u/s.11 of the Act in the light of the fact that there is no violation of either 11(5) or 13 of the Act in the case of the assessee as has been held by the Pune Bench of the Tribunal in assessee’s own case [2013 (9) TMI 1120 - ITAT PUNE] in the 12A matter. Therefore, addition made was deleted by the Ld. CIT(Appeals). - Decided against revenue.
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