Assessee trust is  engaged in running school and registered under section 12A/12AA.  During year it derived gross income by way of dividend, interest and capital gain and incurred expenses  on running of school and claimed surplus as exempt under section 10(23C)(iiiad).  Assessing Officer allowed exemption. Revision proceedings Commissioner held that  since there was no receipt of assessee from educational institution/activities and it had surplus  receipts, it was not existing solely for purpose of education and exemption had wrongly been allowed. On appeal the Tribunal held that since as per trust deed assessee was engaged solely for running school in which no fee was being charged from students and it had accumulated surplus for purpose of future application to set up schools, provisions of section 10(23C)(iiiad) were applicable to assessee and its income is  exempt. (AY. 2017-18)