Allowing the appeals the Court held that  the assessee claimed to be a charitable society and obtained certificate under section 12A of the Act. It was not in dispute that the entire amount received as “contribution” had been shown in the income and expenditure account. The denial of benefit under section 11 of the Act was on the premise that the donations received were not voluntary in nature, but in the nature of capitation fees and therefore, taxable in the hands of the assessee. In each year of assessment, the Assessing Officer had to examine the case independently. For the assessment year 2011-12, the Assessing Officer had held that he had made enquiry with the parents and collected information that the amount was not made voluntarily. Should there be any violation with regard to receipt of capitation fee, the Assessing Officer could not have denied the benefit under section 11 of the Act so long as the certification was in force and admittedly, the assessee’s certificate was in force. Though the certificate was cancelled by the Revenue it had been restored by an earlier order of the court.(AY.2009-10 to 2011-12)