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7. As per the Trust Deed, the fees collected would be used for future expansion of the schools and that the petitioner trust would establish a hundred schools before 2014. The 2nd respondent noticed that the fee structure was not governed by the government regulations and as such it cannot be said that the objective of the petitioner’s trust was Charitable in nature as has been envisaged in Section 2 (15) of the Income Tax Act, 1961.