Dismissing the appeal of the revenue the Court held the association has not been earning any profit as the main object of the assessee-association is to improve the public transport system in the country and the road safety standards. Undoubtedly, the activities of laboratory testing and consultancy are bringing revenue to the assessee-association but the intent of such activities is not to earn profit for its shareholders/owners. No question of law Followed  Ram Kumar Aggarwal & Anr. vs. Thawar Das (through LRs), (1999) 7 SCC 303 has reiterated that under Section 100 of the Code of Civil Procedure the jurisdiction of the High Court to interfere with the orders passed by the Courts below is confined to hearing on substantial question of law and interference with finding of the fact is not warranted if it involves re-appreciation of evidence. there is no perversity in the findings of the ITAT. Referred  State of Hryana & Ors v. Khalsa Motor Ltd  (1990) 4 SCC 659, Hero Vinoth (Minor) v. Thawar Das Through LRs (1999) 7 SCC 303.