The Tribunal held that a public charitable trust cannot be regarded as a concern in which common trustees have a substantial interest merely because the donor and donee trusts have common trustees. Unless it is established that the funds of the donee trust were utilised for the personal benefit of the trustees, exemption under section 11 cannot be denied. While donation to one trust was allowed, the issue relating to another donee trust was restored to the Assessing Officer to examine whether the donation furthered the assessee’s charitable objects. (AY. 2017-18 & 2018-19).