Sec. 2(15) of Income-tax Act, 1961— Charitable trust— Test to determine as to what would be a charitable purpose within the meaning of s. 2(15) is to ascertain what is the dominant object/activity. The Court has observed that if the dominant object is the activity of providing education, it will be charitable purpose under s. 2(15), even though some profit arises from such activity, therefore, assessee's contention regarding applicability of proviso to s. 2(15) requires examination. further, assessee's claim of exemption under s. 10(23C)(iiiab) or 10(23C)(vi) also requires examination keeping in view the orders passed by the learned Chief CIT, Mumbai, under s. 10(23C)(vi) and also considering the fact that the assessee has been recognized as a deemed university and receiving substantial grant from the Government, since the aforesaid claim of the assessee has not at all been examined by the Departmental authorities, the issue was restored to the file of the AO for re-examination and direct him to adjudicate the issue keeping in view the additional evidences filed by the assessee and it was clear that the AO must consider all the contentions of the assessee with regard to the applicability of the proviso to s. 2(15) as well as the claim of exemption under s. 10(23C)(iiiab) or under s. 10(23C)(vi)  and the AO must provide reasonable opportunity of being heard to the assessee before deciding the issue through a speaking order— Institute Of Chemical Technology vs. ITO [2020] 203 TTJ 590 (MUM)