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:- 24 -: ITA 1332/10 & "... a solitary instance of application of income from the schools for non-educational purposes in a prior year was not very material. The fact that the assessee trust had objects other than educational objects was also not material..."

Pinegrove International Charitable Trust vs. Union of India and Others - 327 ITR 73 (P&H) "...Merely because profits have resulted from the activity of imparting education that would not change the character of the institution existing solely for educational purpose ..."

27. The ld.AR has relied on a line of decisions below, which have held unequivocally that 'education' per se is 'charity' and that there are no strings attached.

:- 28 -: ITA 1332/10 & P.C. Raja Ratnam Institution vs. Municipal Corporation of Delhi & Others - 181 ITR 354 (SC) "...Test of charitable purpose satisfied by proof of any of the three conditions of relief of poor, education or medical relief...."

DIT vs. Garden City Educational Trust - 330 ITR 480 (KAR) "... so long as a trust has education as one of its objects which is one of enumerated heads which qualifies and comes within scope of charitable purpose as enumerated in section 2(15), it has to be accepted that trust is having a charitable purpose as its object and may qualify for claiming exemption in terms of sections 11 ...."

ACIT vs. Surat City Gymkhana - 300 ITR 214 (SC) "... Charitable trust - registration - further probe into objects after registration - not permissible ..."
"...The registration of a trust under section 12A of the income tax act, 1961, once done is a fait accompli and the Assessing Officer cannot thereafter make further probe into the objects of the trust ..."

Hiralal Bhagwati vs. CIT - 246 ITR 188 (GUJ) "... Once the registration under section 12A(a) of the Act was granted, the income tax officer was not justified in refusing the benefits on the ground that it was not for the benefit of the public at large ..."

:- 57 -: ITA 1332/10 & "... The role of the Assessing Officer in such cases stops here. But he cannot go further overruling a superior authority to hold that the trust or institution is not established for charitable purpose. Therefore, the Assessing Officer has exceeded his jurisdiction in saying that the assessee is not entitled to exemption under sec. 11. He can say so, only when the income is not applied for the stated purpose, but not otherwise ..." ITO vs. Trilok Tirath Vidyavati Chuttani Charitable Trust - 90 ITD 569 (CHD) "...When once the character of the institution being charitable is accepted by the Commissioner at the time of granting registration, the Assessing Officer cannot question the charitable character of the institution at the time of completing the assessment and the assessee cannot be denied exemption in respect of income on the ground that it is not a charitable institution ..." Calicut Islamic Cultural Society vs. ACIT - 28 SOT 148 (COCH) "... Once the registration is granted to the assessee by the Commissioner of Income Tax, Assessing Officer cannot go into probing the objects and the purposes of the trust or institution and that is within the exclusive domain and jurisdiction of the Commissioner of Income Tax. What Assessing Officer can do that he can at the most investigate the matter within the four corners of sec. 13. In this case the Assessing Officer has gone with investigating and probing the basic objects of the trust by entering into shoes of the Commissioner of Income Tax and such exercise is not permissible ..." ITO vs. Baba Dhall Educational Society of India - 27 SOT 391 (DEL) "...Once registration was granted by the CIT under sec. 12AA, it could not be said that the objects of the trust were not charitable - on the date when assessment was framed, the order of CIT registering the trust under sec. 12A / 12AA was available with the Assessing Officer ..."