Assessee is an apex co-ordinating body of all nationalized State Road Transport Corporation working under aegis of Ministry of Road Transport and Highways, Government of India. Its main object was to improve public transport system in country. It also earned   revenue from laboratory testing of automobiles and consultancy services. Dismissing the appeal of the revenue the Court held that   merely because the  had receipts under head revenue from testing laboratory and consultancy receipts which were of commercial nature, it could not be said that activities of assessee did not fall under categories of education, medical relief, relief to poor, preservation of environment and, hence, assessee-association was charitable in nature.