Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahu
iiiad) and (vi) maybe summed up as follows: :- 17 -: ITA No. 368/CTK/2019 and others Roland Educational & Charitable Trust, Berahampur (1) Where an educational institution carries on the activity of education primarily for educating persons, the fact that it makes a surplus does not lead to the conclusion that it ceases to exist solely for educational purposes and becomes an institution