Held that the findings of the Commissioner (E) were based on surmises because at this stage the commercial angle of any activities could only be decided during the assessment proceedings. It was a matter of fact that medical research had to be carried out in the premises of the hospital/settler company and any such medical research would otherwise facilitate the general public to have a specialised treatment in the hospital of their choice. Medical research could not be branded as a mode of advertisement to enhance the profitability of the hospital because both existed in entirely separate domain. Declining the registration on the ground that medical research to be carried out in the hospital of settler company would convert the charitable activities into commercial activities was mere surmise, and not sustainable in the eyes of law.