(1.) THIS is a Revenue appeal, following grounds are raised:
(2.) BRIEF facts are that the assessee foundation was incorporated with the objects of developing the expertise in scope and level of imparting of science education in the medium of Govt. approved schools. To achieve these laudable objects it developed 'course resource material (CRM)' for the students who keen in learning science education. By this education model, the willing students are registered with the institution. This registration is done through recognized schools and colleges spread across India. Such schools include mainly Kendriya Vidyalaya, Jawahar Navodaya Vidyalaya, Government Schools, DAV schools and other recognized schools across all over India. Such schools from where students are registered total upto more than 7500 schools who carry out the registration of the students for CRM on behalf of the assessee foundation.
(3.) LD . counsel for the assessee in reply reiterated the facts and contends that ld. AO ignored the history of past assessments framed u/s. 143(3) wherein after proper verification of record, its activities were held to be educational as well as charitable in nature and benefits of sec 11 were allowed.