Allowing the appeal of the assesse , the Tribunal held that ; Charging of fees for educational activities which has to be applied for the object of the trust has to be seen as application of income. There is no disharmony between S. 10(23C) and S. 11 and exemption cannot be denied. ( AY. 2011-12)
Adarsh Public School v. JCIT ( 2018) 169 ITD 255 ( Delhi) (Trib)
S. 11 : Property held for charitable purposes – Charging of fees for educational activities which has to be applied for the object of the trust has to be seen as application of income -There is no disharmony between S. 10(23C) and S. 11 and exemption cannot be denied .[S. 10(23C) 12, 12A ]