Proviso to section 2(15),introduced by the Finance Act, 2008 with effect from 1‐4‐2008 ,applies to trust which has object of 'advancement of any other object of general public utility' and does not apply to other categories of charitable trust i.e., relief to poor and medical relief.

Krupanidhi Educational Trust v. DIT(IT) (2012) 139 ITD 228 (Bang)(Trib.)