Held that Consultants  were appointed for a specific period of 5 years for a specific remuneration. Except providing consultancy services with regard to specific project, they were not involved in any kind of day to day managerial functions. Tribunal held that the consultants could not be considered as managers of trust falling within ambit of section 13(3)(cc) and  they were provided with interest free loan as per terms of their employment. Denial of exemption was held to be not justified. As regards the trust  allows any benefit to interested persons in violation of section 13(1)(c), then only that part of income which is in violation of section 13(1)(c) is chargeable to tax at maximum marginal rate of tax; but not whole income of trust.  (AY. 2012-13, 2013-14, 2016-17, 2017-18)