The assessee is a trust registered under the Bombay Public Trust Act and also under section 12A of the Act. The Assessing Officer treated the trust as mutual association and denied the exemption. On appeal the CIT(A) held that receipt from non-members are not eligible for exemption on the principle of mutuality, denied the exemption u/s 11 and treated the receipt as business income within the meaning of the proviso to section 2(15) of the Act. On appeal the Tribunal held that the activities of the Trust cannot be termed as commercial activities. Tribunal also held that  proviso to section 2(15) which restricts scope of term charitable purpose applies only in respect of any other object of general utility and not in respect of relief to poor, education, medical relief etc.  The exemption cannot be  declined merely on ground that assessee has received consideration for sale of training material or journal etc. incidental to furtherance of its objective of imparting education.  (AY. 2011-12)