Court held that the Chief Commissioner had not brought on record any evidence for holding that the expenditure incurred did not relate to the educational activities of the assessee-trust, which ran a school. The expenditure incurred to the extent of Rs. 6,00,763 for awareness on agriculture, Rs.55,000 for medical camps and Rs. 27,480 for eye camp activity could very well be part of the activities carried out in the school itself. A mere reference to the expenditure incurred and the head of expenditure in question while rejecting the application under section 10(23C)(vi) was not enough to reject the application under the provisions of the Act. The Tribunal was wrong in confirming the order . Matter remanded to the Chief Commissioner.