Allowing the appeal the Tribunal held that even if some rental income which was earned with the intention of applying it for charitable purpose and educational activity, the AO is justified in accepting the claim of the assessee treating the gross receipts having been earned from carrying out educational activity.  The order of the AO is neither erroneous nor prejudicial to the interest of the Revenue.  Judgment in New Noble Educational Society v. Chief CIT (2022) 448 ITR 594 (SC) will operate prospectively from 19th Oct., 2022.  Prior to the said judgment of the apex Court, the ratio laid down by the jurisdictional High Court in  DIT  (E) v. Sahu Jain Trust (2011) 243 CTR 131 (Cal) (HC) was  applicable. Revision order is quashed and set aside.. (AY.2018-19)