Trust can adjust its excess expenditure in earlier years against income of subsequent years:

Assessee adjusted its excess expenditure incurred in earlier years against income of the year under consideration. AO denied such an adjustment. On appeal, both the lower authorities directed AO to allow the adjustment of excess expenditure in earlier years against income of year under consideration. The said view was also upheld by the Hon’ble High Court. Revenue’s appeal was dismissed accordingly.

[CIT Vs. OSHWAL EDUCATION TRUST - TAX APPEAL NO.391 of 2012 - GHC]