Section 2(15), 11 of the Income-tax Act, 1961 — Charitable purpose — A surplus arising from activities would not necessarily mean that institution is being carried on 'for profit' — In the case of assessee, in order to carry on the charitable object, it is necessary to charge certain fee or consideration for the services rendered and such an act of trust cannot give colour of trade, commerce or business to the solemn objects carried out just for the reason that fee or charges are being recovered as the income of the trust are being stated to be ploughed back for the furtherance of objects of the trust, such activities would not portray the character of commercial nature,therefore, applying the principles, the activities of the trust cannot be deemed to be a commercial venture, thus, the activities of the assessee cannot be excluded from the ambit of definition of Section 2(15) where the registration of the assessee is in force and in result, assessee would be entitled to deduction under s.11  on surplus as claimed— Gujarat Safety Council vs. ITO [2020] 180 Itd 711 (AHD).