Sec. 12AA of the Income-tax Act, 1961 - Charitable or religious trust - The assessee filed an application under Section 12AA of the Act in form No.10A for grant of registration but the CIT(E) rejected the said application by noticing, inter alia, that the assessee was operating on commercial principle and had amassed capital funds of Rs. 5.59 crores and fixed assets to the extent of Rs. 5.85 crores since it started its operation in 2007; the emphasis of the society was mainly on creation of assets rather than on re-deployment of funds towards education and to add their vehicles and buses; the transportation charges being earned by the assessee were approximately 40% of the fee income received from the students and the fee structure was not in sync with the instruction issued by the CBSE while providing affiliation to an entity; and that the assessee had faltered on statutory requirements of filing returns of income despite receipts in excess of Rs. 2 crores every year. The Tribunal allowed the appeal and directed the CIT(E) to grant registration to the appellant-society forthwith, i.e. from the date of application. High Court dismissed the appeal of the revenue holding that ”No question of law, much less, the substantial question of law arises in this appeal“. Supreme Court dismissed the Special Leave Petition of the revenue. - CIT V/s RURAL EDUCATION & WOMEN WELFARE SOCIETY, SAS NAGAR - [2020] 269 TAXMAN 466 (SC)