Court held that the Settlement Commission committed an error while adjudicating upon the rectification application filed by both parties. The Settlement Commission, arbitrarily and irrationally based its adjudication on the order dated January 16, 2018, passed by the Department. Thus modification of the original order dated June 30, 2017 on that count was completely perverse and contrary to the provisions of the law. At the time of passing of the original order, the assessee was a registered entity under section 12A and withdrawal of the approval accorded under section 10(23C)(v) and (via) as a consequence of cancellation or withdrawal thereof could not have retrospective effect. Court also held that the Settlement Commission held that section 11(6) restricts the assessee from claiming depreciation. The Commission lost sight of the fact that the provision was inserted in the 1961 Act on April 1, 2015 and therefore, it could only be applied prospectively. Depreciation in respect of the expense claimed by the assessee was for the assessment years 2009-10 to 2014-15  the assessee was entitled to all the benefits under section 11(1)(a) including set off or carry forward of losses to the subsequent years and depreciation, in respect of expenses incurred for construction of educational buildings in terms and tune with the objects of the trust.  The television channel was acquired by the assessee for educational training in journalism and mass communication, as it was offering courses for graduation and post-graduation in “mass communication” and “Journalism”. The investment in the television channel should be considered to be in consonance with the objectives and within the purview of the objects of the trust. (AY. 2009-10 to 2015-16)