Allowing the appeal of the revenue against the order of single Judge the Court held that ,assessee is  engaged in imparting education, application for exemption under sec. 10(23C)(vi) was allowed without considering revenue’s objection that assessee had disproportionate fee structure which was devised to earn maximum money for purpose of expansion of institution which did not fall within ambit of charitable activity, impugned order was to be set aside and, matter was to be remanded back for disposal afresh after considering the ratio in American Hotel & Lodging Association Institute v CBDT ( 2008) 301 ITR 86 (SC) and Queen’s Educational Society v CIT( 2015) 372 ITR 699 ( SC) .