A charitable trust is created for the benefits of the public at large. Exemption from the tax given to the charitable trust because their object is to serve mankind. Sometimes trust was formed for a charitable purpose but along with it, they are also engaged in the business or commercial activities, in such case it would be difficult to draw the distinction between income applied for charitable purposes or, business or commercial activities. Education has also come under the meaning of charitable purposes; therefore, educational institutions are also entitled to get an exemption from the tax. Where an educational institution generates a surplus and invests in fixed assets which were properties of educational institution, exemption from the tax should not be refused. If the educational institution ploughed back the surplus for educational purposes or used the new assets for educational purposes, then said the educational institution was considered to have existed solely for educational purposes only and not for profit.
