Dismissing the appeals and allowing the petition, the court held that , Merely because surplus profit earned in educational activities did not automatically presuppose a business activity that invalidated the exemption as long as surplus was utilised for charitable purposes .The assessee which maintained its eleven schools and the 120 satellite schools in furtherance of the education joint venture agreements with an educational purpose, that also was qualified as “charitable purpose” within the meaning of S.2(15) and was not in contravention of S. 11(4A) . (AY.1998-99, 2008-09 )