Assessee-trust is  registered under Societies Registration Act for advancement and promotion of science and technology by developing science city project. Assessing Officer rejected assessee’s claim for exemption under section 11 holding that activities carried on by assessee qualified as general public utility, carried out in a commercial manner and thus, did not qualify as a charitable activity in terms of section 2(15).  Commissioner (Appeals) held that activity carried out by assessee qualified as ‘education’, in terms of section 2(15), and thus assessee was entitled to claim exemption under section 11. On appeal the relying on the judgement of  Apex Court in case of New Noble Educational Society v. Chief CIT (2023) 290 Taxman 206/ (2022) 448 ITR 594(SC) held that  very clear terms held that education means imparting formal scholastic learning for purposes of qualifying as charitable purposes under section 2(15)-Whether therefore, in view of narrow and restricted meaning given to term ‘education’ as used in section 2(15), activities carried out by assessee being primarily run as a science museum did not qualify as education and order of Commissioner (Appeals) holding so was to be set aside.  Tribunal also held that  activities carried out by assessee were not in nature of imparting education, but were in nature of general public utility activities in terms of section 2(15), matter was to be remanded back to Assessing Officer for purpose of determining whether they were commercial in nature so as to disqualify them from being charitable activities in terms of first and second proviso to section 2(15).  (AY. 2013-14)