2011 (6) TMI 465

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....1, has been rejected. 2. The assessee is a trust registered before the District Registrar, Chennai pursuant to the deed of declaration of trust executed on February 11, 2009. The object of the assessee-trust is to run educational institutions with modern methods to improve the education. 3. But the application was rejected by the Director of Income-tax (Exemptions) on the ground that the probable fees to be collected from the students is having a component for the future expansion of the institutions and this component is in the nature of profit and therefore, the objects of the trust will also include profit motive, as found in clause 11 of the trust deed. The assessing authority has also observed that the assessee-trust wants to est....

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....are in agreement with the view of the Director of Income-tax (Exemptions) that the fee structure of the assessee-trust itself contemplates element of profit in the activities to be carried on by the assessee. 8. At the time of hearing of this appeal, a clarification was sought from learned counsel appearing for the assessee, whether the assessee is imparting free education to the poor section of the public and whether the assessee has provided any fee concession to deserving students. It was submitted before us that the only concession given by the schools run by the assessee-trust is in respect of fees collected from the wards of the teachers of the institutions. It shows that the assessee is collecting fees from all children and no fre....