Dismissing the appeal of the revenue the Court held that clause (c) of sub section (2) of section 13 can be invoked , if any amount is paid by way of salary , allowance or other wise to any person referred in sub -section (3) out of resources of the trust for services rendered to the trust and the amount so paid is in excess of what may be reasonably paid for such services . The essential requirement  for invoking the said provision is that the amount paid was in excess of what may be reasonably paid for the services .On fact the Tribunal  has held that payments made to other agencies for similar work , comparable rates of payment made to related person . Accordingly no substantial question of law .( AY. 2008 -09, 2009 -10)