The Assessee claimed an exemption u/s 11(1)(a) at the rate of 15% of its gross receipts and claimed balance deficit being excess of expenditure over receipts to be carry forward to subsequent years. AO rejected the claim of the Assessee u/s 11(1)(a) on the basis that since there was excess of expenditure over gross receipts the assessee is not entitled to any  accumulation  as there is no surplus receipts left after application for current year. Accordingly, no carry forward of deficit was allowed to be carried forward to subsequent years either. CIT(A) held that the claim u/s 11(1)(a) is unfettered and the said section does not lay any specific condition for allowability  of such exemption and set aside AO’s order. The ITAT upholding the CIT(A)’s order further relied upon the order of Supreme Court in case of Subros Educational Society [(2018) 303 CTR 1 (SC)  held that any excess expenditure incurred by trust in earlier assessment year  would be allowed to be set-off against income of the subsequent years. (AY 2015-16)