No cancellation of registration as cash deposited in old denomination notes was from fees collected from students

Where registration of assessee educational society under section 12AA was cancelled on ground that huge cash amount belonging to assessee in old denomination notes was found during search on premises of assessee's bank where management of assessee had effective control and same was kept there with an intention to get it exchanged with new currency, since source of such cash was established to be fees collected from students and such fees was recorded in books of account and cash was physically found in possession of assessee's bank, impugned withdrawal of registration was unjustified

Where assessee educational society had given scholarship to several students and had produced several documents in support of said scholarship payments, mere non-appearance of certain students for verification could not be a sole basis to held that scholarship payments were not genuine so as to withdraw registration granted to assessee under section 12AA

Where assessee educational society had purchased a plot of land and built a school building thereon and carried on its educational activities and fees so received was reflected in its books of account, it could not be said that assessee had made investment in contravention of section 11(5) so as to withdraw registration granted under section 12AA

Refer:[2019] 104 taxmann.com 387 (Jaipur - Trib.)