Dismissing the appeal of the revenue  the Court held that  the activity performed by the assessee was inseparably linked to the “charitable purpose” of providing mid-day meals at village schools. The total receipts of the assessee were below the limit of Rs. 10 lakhs as stipulated under the second proviso to  S.2(15) of the Act. Therefore, the Tribunal had rightly concluded that the restriction created by the first proviso to S. 2(15) of the Act did not operate against the assessee and therefore the activity of the assessee, even though it might have involved an activity in the nature of trade, commerce or business, would fall within the ambit of general public utility and therefore be a charitable purpose under S. 2(15) of the Act.