The petitioner-assessee filed an application dated 27.9.2009 in Form 56-D seeking grant of exemption/approval under Section 10(23C) (vi) of the Act on the ground that it was a society registered on 16.9.1992 under the Society Registration Act, 1860 and for the last 18 years engaged in the activity of providing education and relied upon aims and objects mentioned in the Memorandum of Association to press forth the ground that it exists solely for education purposes and not for purposes of earning profit. Information was sought by the office of the Income Tax Officer from the petitioner society on 4.5.2010 whereby it was asked to furnish various information including activities undertaken by the petitioner society, list of trustees and copy of accounts etc. The said information was accordingly furnished on 17.5.2010 to the Income Tax Department and it was also brought to the notice of the said officer that the petitioner society was running two schools at Hansi and details of strength of students and ownership of lands and rooms was also given. Thereafter, fresh information was asked for on 20.9.2010 vide Annexure P-6 as to whether the society exists solely for education purposes or it has other activities also which were not related to education. The petitioner was also asked to explain the surplus for the last three assessment years i.e. 30.54%, 45.32% and 48.8%, and the petitioner was asked to analyse the above profit with respect to utility thereof. Accordingly, detailed reply was submitted on 22.9.2010 and stress was laid down that aims and objects of the society were mainly in the context of imparting education and for establishing schools, hostels, libraries, reading rooms and play grounds etc. And further that income was not to go to the members of the society in any manner rather the society exists solely for imparting education and falls
