On appeal the High Court held that the assessee-trust was not entitled to exemption  because the funds of the trust were being misutilised and misappropriated in the name of the managing trustee and chairman and his family members and the expenditure was incurred towards the house of the managing director and chairman-cum-managing trustee and huge amounts had been spent in the name of the family members of the managing trustee, the purchase of dental equipment for the college was not supported by valid receipts and documents, properties were purchased in the name of the managing trustee, the documentary evidence showed that the receipts were in the name of the trust and the collections of donations amounted to profit-making motive which could not be the object or the purpose of running a charitable educational institution.  On appeal Supreme Court affirmed the order of the High Court. (AY. 1997-98)