‘Such income’ in Section 11(1)(a) stands for ‘Gross Income’ not ‘Net Income’

Facts of the Case

The assessee is an educational society and it obtained registration under the provisions of section 12A of the I.T. Act. For the year under consideration, it filed its return of income wherein NIL income was declared after giving effect to provisions of section 11 of the Act. The AO noticed that the assessee received gross amount of Rs.2,96,29,585 in the form of tuition fees from students, interest on deposits and miscellaneous income. Out of the said receipts, a sum of Rs.2,39,10,198

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