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8. Investment in shares of Baron Air by the schools/societies can not be termed as an educational activity (MS-1, Annexure A-84).

9. Vehicles of the schools/societies are used by Shri V.K.Bhatnagar and family members.

10. Salary is being paid to Anurag Bhatnagar while he was a student and Vikram Bhatnagar from various schools and societies. Substantial salary of Rs.6.71 lacs is being paid to Smt.Mamta Bhatnagar as a Principal whereas other Principals are getting nominal salaries of Rs.15,000/- p.m.

3. The allegation is without any basis. AO has not pointed out any receipt, which is no accounted for rather he has relied on the receipt shown in the books of accounts for taking the surplus.

4. The land has been exchange in execution of the decree of the court. The land so exchanged is used by the society for educational activities without any charge.

5. No share of Baron Air Ltd. is purchased by the assessee society/school.

(v) In para 5 at page 28 of assessment order the AO has alleged that cost land of Societies have been transferred to Shri VK Bhatnagar and his family members. No land has been exchanged by the assessee with Bhatnagar as is clear from the observations of the AO at page 12 of his order of assessment giving details of land exchanged by various societies with Bhatnagar. The property of Manav Sthali School, Pusa road, was exchanged and not that of the assessee.

(vi) In para 6 at page 28 of his order, the AO has alleged that the share in Baron Air Ltd., Purchased by Societies/School cannot be considered as educational activities. These observations are not correct because there was no such investment by the assessee. The seized document referred to by the AO in this regard does not pertain to the assessee.

In exchange, the inferior quality of lands situated at interior villages at Raisina was given to the Society.

f) Investment in shares in Baron Air Limited No share of Baron Air Ltd. is purchased by purchased by Societies/School cannot be the assessee society/School. termed as educational activities.

g) The vehicles of the school/societies are This observation is without any basis. Even used by Shri V.K. Bhatnagar & family. otherwise, the vehicles are used by them only for educational purpose. This has no relevance with the exemption u/s 10(22)