K.L. Manjunath, J.— This appeal is by the Revenue challenging the order passed by the Income Tax Appellate Tribunal, Bangalore Bench, in I.T.A. No. 816/Bang/2002 dated August 26, 2003, for the assessment year 2000-01.

2. The facts of this case are as hereunder:

3. The assessee is a company incorporated under the provisions of the Companies Act, 1956 to impart education. The assessee has entered into an agreement on November 10, 1999 with IITC, which is an educational institution situated at Chicago in order to impart distance education in certain faculties. As per the terms and conditions of the agreement, IITC has to impart education on certain faculties under a programme, known as Distance Education Programme for which the assessee-company has to provide infrastructure like collecting the application forms and forward the same to IITC, for the purpose of admission and after approval of admission, to collect the tuition fees and remit the same to IITC, USA and receive the education materials from IITC, and in turn pass on the same to the students admitted by IITC in Bangalore. In other words, it has to act as a liaison office between the students who have been admitted by II