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This appeal by the assessee is directed against the order of the Director of Income-tax (Exemptions) [DIT(E)], Hyderabad dated 30.08.2012.

2. The assessee's grievance in this appeal is with regard to non-granting of registration u/s. 12AA of Income-tax Act, 1961.

3. The assessee applied for registration u/s. 12AA of the Act vide form No. 10A on 29.2.2012. The DIT(E) called for details to satisfy himself regarding genuineness of the activities carried on by the assessee. It was submitted by the assessee society that the assessee society after its incorporation, has established two colleges viz., Sahasra Institute of Pharmaceutical Sciences in the year 2006 and Sahasra Engineering College for Women in the year 20.09. It was stated that these colleges have been established in Warangal District of Andhra Pradesh and are run with non-profit motive. As per the Income & Expenditure Account for the year ended 31.3.2011 i.e., for the period 1.4.2010 to M/s. Sahasra Educational Society ========================== 31.3.2011, the assessee society has shown excess of income over expenditure at Rs. 37,48,715. In that account, the assessee has shown income from Bus Fee, Hostel Fee, College Fee, Tuition Fee, Examination Fee, in addition to interest on savings bank account and Pharmacy Remuneration Fee. The income from college fee and tuition fee from both the engineering and pharmacy colleges as shown by the assessee society in that income and expenditure account for the year ended 31-3-2011, are as under:

5. The assessee also furnished a copy of GO Ms. No. 76 dated 13-8-2010 issued by Government of Andhra Pradesh, Higher Education Department, as per which the tuition fee for under-

graduate engineering courses including pharmacy courses in private un-aided institutes in the state for the academic years 2010-11 and 2011-12 were fixed at Rs. 31,000/- per annum per each student for 'A' .category seats and Rs. 95,000/- per each student other than NRI students in 'B' category seats. Clarifying about both types of seats, vide letter dated 17-8-2012, it was submitted by the assessee that, in 'A' category the respective seats of the college shall be filled by conducting counselling and in 'B' category the respective seats of the college (30% of the sanctioned intake) shall be filled by the management. In that letter, it was further stated that there is no fee structure issued by Kakatiya University and JNTU and both these universities will follow the fee structure issued by the Andhra Pradesh Higher Education. Further stating that the college fee, bus fee, hostel fee, library fee and tuition fee per student in respect of the engineering college during the financial year 2010-11 were at Rs. 5,500/-, Rs. 7,500/- Rs. 22,500/-, Rs. 7,500/- and Rs. 30,200/- respectively, the amount of fees collected by the assessee society from such sources from the students of the engineering college during that year, were furnished as under:

                            Direct incomes               Amount (Rs.)
                 Scholarships for tuition fee               14155925
                 Engg. Bus fee                               1223229
                 Engg. College fee                           2152350
                 Engg. Hostel fee                            1699920
                 Engg. Library fee                            205500
                 Engg. Management fee                         771400
                 Engg. Tuition fee                           1574600
                 M. Pharm tuition fee                         165000
                 M. Pharm College fee                          90000
                 Pharmacy college fee                         690700
                 Pharmacy Hostel fee                          164000
                 Pharmacy Management fee                      260900
                 Pharmacy tuition fee                         281600
                                                            23435124


                                          M/s. Sahasra Educational Society
                                          ==========================

11. From the above, It may be seen that the assessee has not shown any single amount towards total tuition fee received from the engineering college during that year. Excluding the amounts shown as college fee, hostel fee and library fee, if the three other receipts from scholar-ships for tuition fee, Engg. Management Fee and Engg. Tuition Fee are considered as towards tuition fee during that year, the total of those amounts i.e., aggregate of those three receipts, which comes to Rs. 1,65,01,925/-, cannot be considered as the actual total receipt from tuition fee collection from that engineering college during that year, in view of the detailed discussions made in para 6.1 above. To put it differently, the assessee society has not disclosed the actual receipt from tuition fee collection made from students during the financial year 2011- 12 in that income & expenditure account.