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"The appellant seek to place on record synopsis in supplement to the arguments addressed during the course of hearing before the Hon'ble Bench. Facts in brief are that the appellant is a charitable trust settled vide Trust Deed dated 1.02.2001 for the predominant charitable object of imparting education. The appellant-trust was initially declared/setup in the name of 'Ram Krishan Kulwant Rai Charitable Trust' and subsequently, the name of the trust was changed to IILM Foundation vide amendment of Trust Deed dated 26th July, 2007.

• It will thus, kindly be appreciated that payment of Rs.2. 72 crares for purchase of land to WBHIDCO, was, in fact, made for acquisition of land by the assessee itself and was not made on behalf of RKSCT, as incorrectly inferred by the assessing officer.

• The contention of the assessing officer that the assessee had utilized funds for acquiring assets on behalf of another trust is, thus, factually incorrect.

Re (b): Loan to RKSCT • As regards loan of Rs.2.19 crares, it is submitted that the said loan was given by the assessee to Ram Krishan & Sons Charitable Trust (,RKSCT'), another charitable trust having similar objects.

Copy of registration certificates under sections 12A and 80G the Act issued to RKSCT [refer pages 134-137 of the paper book];

- Trust Deed of RKSCT [refer pages 126-133 @127 of the paper book];

• It may also be pertinent to mention here that the assessee is duly empowered under the Trust Deed to aid and assist any other charitable trust [refer clause 5(a)(i), (iii) and (xiii) at j pages 2-3 of paper book).

In the aforesaid facts, there was no violation of section 13 of the Act on account of advancing loan to another charitable trust having similar objects. • Reference, in this regard, may be made to the following decisions wherein it has been consistently held that giving of loan one charitable trust to another charitable trust amounts to application of income for charitable purposes- DIT(E) vs. Pariwar Sewa Sansthan: 254 ITR 268 (Del.) [refer pages 38 - 39 of Paper Book of case laws].

3.4 In the trust deed, there is no clause of extending loan. The reliance of assessee on 'assistance' is far-fetched.

3.5 As per clause 5 (a) (iii) of the RK & Sons Charitable trust is having objects to open, found (sic), establish, equip, finance, assist, maintain, or contribute to technical, industrial, or commercial concerns, institutions, associations, or bodies imparting any type of training or providing employment to persons. (ref: page #127 of PB filed in ITA No. 1214/Del/2011).