(Per : HONOURABLE MR.JUSTICE V. M. SAHAI)
1. We have heard Mr. M.R.Bhatt, learned Senior counsel assisted by Ms.Mauna M.Bhatt, learned counsel appearing for the appellant.
2. Admit. We formulate the substantial question of law as under:
1. Whether the Appellate Tribunal has substantially erred in law in deleting the addition of Rs. 1,90,19,319/- ignoring that the receipts from the students at the time of seeking admission was not towards the corpus of the Trust but was for the service rendered by the school to the students and hence income of the assessee ?
2. Whether the Appellate Tribunal has substantially erred in law in holding that the assessee is entitled to exemption under section 11 of the Act despite utilisation of Trust Funds for the purposes other than the Charitable objects of the Trusts as also applicability of section13(1)(c) of the Act ?
3. Issue notice to the respondent. Paper book be filed within three months.
(V.M.SAHAI,J) (N.V.ANJARIA,J) ***vcdarji Top