Allowing the appeal the Court held that the amounts paid by the parents of the students admitted to the educational institution of the assessee-trust were payments towards corpus donation and were not collected by way of capitation fees. The Assessing Officer had not conducted any inquiry with regard to examination of parents who had admitted the students in school as to whether the payment was made towards corpus fund or capitation fee. Though it was true that the donation was bound to have been given for material gain in securing admission, it could not be characterised as donation towards charitable purpose and the assessee would not be entitled to have the benefit, but in the absence of any material on record, such view could not be taken. Therefore, the Tribunal had committed an error by treating the admission fees charged from the students as not forming part of the corpus fund of the trust. Therefore, the Tribunal was not justified in confirming the addition of the corpus fund to the income of the assessee by holding that the receipts could not be treated as corpus donation and not eligible for exemption under section 11(1)(d).(AY. 2013-14)