From the trust-deed translated and reproduced in English, the Tribunal found that the assessee carried out all other ancillary activities, such as promotion of cultural, social and sports necessary for building the character of students, and that these were co-related to the main activity of education. It further found that the nominal profit earned by the assessee while it carried out the charitable activities were not with a profit motive and the profit so earned was again utilised for charitable activities by it. Accordingly, the Tribunal held that the other ancillary activities were only to promote the main activity of education, and the nominal profit earned did not mean that the assessee was engaged in commercial activities. On appeal. Order of Tribunal affirmed. (AY. 2019-20)