Charitable purpose under Section 2(15) survives incidental receipts when activities lack profit motive and support the main object.

An entity remains charitable under Section 2(15) where incidental receipts from laboratory testing and consultancy are earned in furtherance of its predominant object and no profit motive is shown. The court noted that the assessee, an apex coordinating body for State road transport undertakings, was meant to improve public transport and assist members at economical cost. Since the concurrent findings below held that the activities supported the main charitable purpose and did not amount to business, trade or commerce, interference was unwarranted absent perversity or a substantial question of law. The exemption-related relief was therefore sustained.

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Issues: Whether the assessee-association remained charitable within Section 2(15) of the Income-tax Act, 1961 despite earning receipts from laboratory testing and consultancy, so as to justify the Tribunal's order allowing exemption-related relief.

Analysis: The assessee was an apex coordinating body of State road transport undertakings with the object of improving public transport and assisting its members at economical cost. The receipt of consideration from laboratory testing and consultancy did not, by itself, establish that the assessee was carrying on business, trade or commerce with a profit motive. The authorities below had concurrently found that the activities were undertaken in furtherance of the main charitable object and that no profit-making intent was established. In appeal, interference with such concurrent factual findings was unwarranted in the absence of perversity or a substantial question of law.

Conclusion: The issue was decided against the appellant and in favour of the assessee; the finding that the assessee's activities did not amount to business, trade or commerce with profit motive was upheld.

Ratio Decidendi: Where an entity's incidental receipts are generated in furtherance of its predominant charitable object and no profit motive is established, the first proviso to Section 2(15) does not apply merely because some consideration is received for such activities, and concurrent factual findings on that question are not to be disturbed absent perversity.

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