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The judgment of this Court in Addl. CIT vs. Surat Art Silk Cloth Manufacturers Association (1979) 13 CTR (SC) 378 :

(1980) 121 ITR 1 (SC), cited by learned counsel for the assessee, was delivered with reference to the true meaning of the words 'not involving the carrying on of any activity for profit' occurring at the end of the definition of 'charitable purposes' in s. 2(15) of the IT Act. This Court said that if the primary or dominant purpose of the trust was charitable, another object which by itself may not be charitable but which was merely ancillary or incidental to the primary or dominant purpose would not prevent the trust or the institution from being a valid charity. The judgment is of no assistance in construing Expln. 3 of s. 80G.