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12. Having perused the order impugned, we find that learned Commissioner has not recorded any finding on the question, as to whether income derived by the petitioner trust is being used for charitable purposes, as per the object of trust or not. Learned Commissioner refused to grant renewal of exemption only on the ground of the source of income. From the perusal of the judgments cited above by learned Counsel for the petitioner, we are of the view that it is not the source of income which is to be seen, but investment of the income. If income is being utilised for charitable purposes as per the object of the trust/society, then exemption ordinarily cannot be refused.

13. Learned Counsel appearing for the revenue has placed reliance on the judgment of the Uttarakhand High Court in the matter of Commissioner of Income-Tax v. National Institute of Aeronautical Engineering Educational Society reported in (2009) 315 ITR 428 (Uttarakhand) and argued that if imparting education is for the primary purpose of earning profit, then it is not a charitable activity. We are of the opinion that judgment of Uttarakhand High Court has no application in the present matter. To grant or refuse the exemption under Section 80G, the main criteria which requires consideration is as to whether income derived, is being used for the charitable purposes, as per the object of the trust/society or not.