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of ITAT denied charitable trust exemption under section 11 due to undisclosed capitation fee receipts. The tribunal conclusively determined that management seat fees collected in cash constituted capitation fees, which are inherently non-charitable. Consistent with precedential rulings, the court rejected the trust's claim for tax exemption, emphasizing that charging capitation fees is incompatible with charitable objectives. The revenue's appeals were allowed, effectively disallowing the trust's exemption claims and rendering the unaccounted cash receipts taxable. Student affidavits were deemed irrelevant, as no individual would voluntarily incriminate themselves regarding fee payment practices.
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