Assessee earned gross receipt of Rs. 61.63 crores on account of educational activity and assessee was also running hostels for students as per UGC Guidelines which was an ancillary activity. Court held that absence of any evidence to show that hostel facilities were provided to anybody other than students and staff of trust, hostel facilities provided by educational institution shall be construed to be incidental to providing education as per object of trust and hence come under charitable purpose.