The object of the Trust is to impart scientific and technical education and research facilities. The Commissioner rejected the application for exemption on the ground that the Trust did not exist solely  for educational purposes. On writ allowing the petition the Court held that there was sufficient nexus demonstrated by the assessee between the expenditure incurred on the incidental activities of providing food, lodging and transport and other facilities to the trainers, the trainees and the staff and the object for which the assessee’s institutions operated. Placement services also associated with education. This could not be completely separated from the essential activity of imparting education and training. The assessee was entitled to exemption under section 10(23C)(vi) in respect of its entire income. (AY.2009-10)