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4. A perusal of the Trust Deed further shows that the object is not just restricted to advancement of education alone. It is stated that during the relevant assessment years, the Trust was running two schools for primary and for higher education in Salem. The Trust has also received corpus donations as per the Will executed by R.Susila, wife of Ramalingam, the author of the Trust. The Trust received donations to the tune of Rs.8,81,500/-, which is lying in deposit with M/s Ramalingam Investments, a sister concern of the Trust. These deposits were made in the sister concern by the testators and not by the Trust. It is stated that the Trust enjoyed exemption under Section 11 of the Act. As regards the assessment years in question viz., 1995-1996 to 1999-2000, the 'nil' returns filed were processed under Section 143(1)(a) and the same were accepted. However, the assessments were sought to be re-opened under Section 147 of the Act on the ground that the Trust had made deposits in a sister concern in which the Trustees were interested and hence, there was violation of the provisions of Section 11(5) of the Act, thereby, attracting the provisions of Section 13(1)(d) of the Act. The assessee, however, pleaded that the Trust received contributions to the corpus only and as per Section 12, such capital receipts should not be brought to tax. The objection taken by the assessee was however rejected, which has resulted in the assessee filing the appeals before the Commissioner of Income Tax(Appeals). The Commissioner of Income Tax (Appeals) remanded the matter back to the assessing authority to consider the case of the assessee with reference to the object clause contained in the Trust deed to examine the claim of exemption under Section 10(22) of the Act.