This appeal by Revenue is directed against orders of learned CIT(A), Karnal dt. 15th May, 2006. Revenue raised following grounds before us: "1. On facts and in circumstances of case, learned CIT(A) has erred in law in allowing exemption under s. 10(23C)(iiiad) to assessee which was denied by AO in assessment order. On facts and in circumstances of case, learned CIT(A) has erred in law in deleting addition of Rs. 9,08,720 made by AO on account of unsecured loans not proved to be genuine." assessee filed return of income declaring nil income. assessee primarily claimed exemption under s. 10(23C)(iiiad) of IT Act. AO denied claim of exemption under s. 10(23C)(iiiad) by observing as under: "This is case of society registered under Society Act, 1860. assessee has filed copy of certificate dt. 18th June, 1987. memorandum o f association and aims and objects of society have been filed by assessee who is on plain paper and photocopy of same has been filed. There is no date of incorporation of memorandum of association and aims and objects. No date has been put anywhere to establish society has been registered on 18th June, 1987 and there is also no date on certified copies which could establish as this is photocopy or original documents. From above, it is clear that society is neither registered with any authority nor under any section of Act which qualify for exemption under ss. 10, 11 and 12 of IT Act, 1961. aims and objects which were registered earlier with registrar of society on 18th June,1987 might have been changed afterwards and it cannot be said that these are same aims and objects of society which were registered on 18th June, 1987. Therefore, this is case of private school which is not entitled to any exemption under ss. 10, 11 and 12 of IT Act. assessee has claimed income as exempt under s. 10(23C) in computation of income attached with return of income. s. 10(23C)(iiiab) or (iiiad) is not applicable in this case as institution is purely private institution which is being run not solely for providing education but for purpose of earning profit." AO also held that there is increase in total fees received in last five years. There is also increase in assets side every year as per two previous years. He, therefore, concluded that assessee is running school not for purpose of providing education for poor and needy children but with object of earning profit. Therefore, school cannot be said to be for charitable purpose under definition of s. 2(15) of Act. During appellate proceedings, certified copies of registration certificate and memorandum of aims and objects were filed. It was also certified that there is no change in aims and objects of memorandum of association of society from day of its inception. Copy of these submissions was forwarded to AO for his comments. AO in remand report reiterated t h e finding given in assessment order. Learned CIT(A), after considering arguments of assessee and remand report submitted by AO, held as under: "The matter has been considered. relevant assessment record has also been looked into. It is seen that photocopy of certificate of registration of societies issued by registrar of firms and societies, Haryana on 18th June, 1987 is available on assessment file of AO. photocopy of memorandum of association is also available on file of AO. appellant has however filed certified copies of these documents before me. copies have been certified by notary public. memorandum of association has also been certified to be true copy by District Registrar of Firms and Societies, Karnal on 28th Dec., 2005. fresh certification of documents already available on file of AO cannot be said to be additional evidence. Copies of various approvals granted by Central Board of Secondary Education have also been filed. perusal of all these documents clearly shows that institution run by appellant society exists solely for education. It cannot be said to be existing for purposes of profit only because it had earned some profit. Since appellant had claimed exemption under s. 10(23C)(iiiad), provisions of ss. 11 and 12 are not relevant in case of appellant. Keeping in view above discussion, it is held that AO was not justified in denying exemption under s. 10(23C)(iiiad) to appellant." Whereas learned Departmental Representative relied upon finding of AO in denying exemption under s. 10(23C)(iiiad), learned counsel for assessee relied upon appellate order. We have considered rival submissions. grievance of AO while denying exemption under s. 10(23C)(iiiad) is that memorandum of association and aims and objects filed by assessee is on plain paper and there is no date of incorporation. However, it is seen that certified copy of certificate of registration dt. 18th June,1987 was filed. society is registered under Societies Registration Act, 1860. It is not case of AO that certificate of registration is bogus. Once certified copy of certificate of registration of society is filed, grievance of AO no more subsists. society is in fact registered with registrar of firms and societies, Haryana under Societies Registration Act, 1860 vide Registration No. 864 of 1988 dt. 18th June, 1987. AO has merely presumed that aims and objects which were registered earlier on 18th June,1987 might have been changed afterwards. However, it is not finding but only presumption. When certified copies filed which shows objects only for imparting education, exemption could not have been denied and presumption that aims and objects might have been changed afterwards. Unless there is clear finding that aims and objects were in fact changed, exemption could not have been denied merely presuming that such objects might have been changed afterwards. assessee having been registered under Societies Registration Act, 1860 cannot be considered as private school or private institution. It is also matter of record that in all earlier years, assessee was held eligible for exemption under s. 10(23C)(iiiad). Though these orders were under s. 143(1)(a), these earlier orders were never disturbed. Even for subsequent assessment year, namely, asst. yr. 2004-05, AO by his order under s. 143(3) dt. 8th Dec., 2006 have held that education is being imparted by assessee without any profit motive and income is exempt under s. 10(23C)(iiiad) of Act. Thus, order of CIT(A) needs no interference. Since assessee is held to be eligible for exemption under s. 10(23C)(iiiad), any income received by such educational institution, which is existing solely for education purpose and not for purpose of profit, is not existing solely for education purpose and not for purpose of profit, is not includible in total income. Thus, ground No. 2 do not survive. In result, appeal is dismissed. *** ASSISTANT COMMISSIONER OF INCOME TAX v. GURU HARKISHAN PUBLIC SCHOOL