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(12) The argument that has been advanced in relation to the assessment year 1971-72 is that since the Society is owning a building and is making profits by letting out flats or rooms in the buildings to various persons it should be held that the? objects of the; Society involve the carrying on of an activity for profit and, therefore, the exemption under Section 2(15) will not be available to the Society. So far as this objection of the Department is concerned it can be considered in two parts. The first is the question whether the- objects of the Society are such that they involve the carrying on of an activity for profit. This has to be clearly answered in the negative because the primary or dominant purpose of. the. Society is only to benefit the press in India in general and as explained earlier none of the object clauses contemplates the carrying, of any activity for profit by the Society. The second aspect to be examined in this connection arises because as pointed out. by the Supreme Court the. inhibition of the exclusionary clause contained in. the. last ten words of Section 2(15), namely. "not involving the carrying on of any activity for profit" would be attracted, if the purpose of the trust or institution, in fact involves the carrying on of an activity for profit or in other, words if an activity, for profit is actually carried on as an. integral part of the purpose or "as, a. matter of advancement of the purpose". In the, present case. if it is assumed that an activity for profit is indulged in by the Society by renting out the various portions of its premises to the members then it is. no doubt true that such activity is carried on as a matter of advancement, of its primary purpose of sub-serving the interests of press in India and of the various member? of the Society. But the expression 'activity for profit' has a restricted meaning as explained by the Supreme Court and the proposition "for" used in it has a very great significance. It is implicit in these words that the activity in question must be carried on with the object of earning profit. It. is not enough merely that same activity is being carried on and it results in a profit. In other words the pre:dominant object of the activity in question should be the making of profit before the inhibition of the last ten words could be attracted. Where an activity is not pervaded by a profit motive but is carried on primarily for serving the charitable purpose it would not be correct to describe it as an activity for profit. But on the other hand if the activity is carried on with the pre-dominant object of earning profit then it would be an activity for profit though it may be carried on in advancement of the charitable purposes of the trust or institution. Where an activity is carried on as a matter of advanccment of the charitable purpose or for the purposes of carrying out. the charitable purpose, while it would be correct to say that the charitable purpose involves the carrying en of such an activity, the predominant object of such activity would be to sub-serve the charitable purpose and not to earn profit. Differing from the observations in the Lok Shikshana Trust's case and the Indian Chamber of Commerce's case referred to earlier, the Supreme Court has pointed out in the rcccnt decision that merely because there is an activity which results in a profit an inference cannot be drawn that the activity is for profit. It is also not necessary that there must be a provision in the constitution of the trust that the activities shall be carricd on a on profit no loss basis or that profits shall be prescribed. Even if there is no such express provision the Court will have to consider the nature of the charitable purpose, the manner in which the activity for advancement of charitable purpose is carried on and other surrounding circumstances and decide whether the activity is propelled by a dominant profit motive or whether the dominant object of the activity is merely to carry out a, charitable purpose.