The Hon’ble ITAT, allowing the appeal, observed that the assessee’s sole object was to provide education to students, the other ancillary activities like promotion of cultural, social and sports were necessary in building the character of the students and were to meet the prime activity of education, that nominal profit earned could not be termed as the assessee trust exists for profit motive, that the State Government has granted the approval to establish and run the secondary and higher secondary studies for the students. The assessee trust entitled to the approval certificate u/s. 10(23C)(vi) of the Act.