Nothing in language of section 13(1)(b) to suggest that an institution of mixed objects is precluded from getting registration under section 12AA

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DECIDED BY:

ITAT, HYDERABAD BENCH `B’,HYDERABAD, IN THE CASE OF: Rehoboth Mission v. DIT (Exemp), APPEAL NO: ITA No. 352/Hyd/2010,DECIDED ON May 26, 2010

HELD
We have gone through the provisions of sec.13(1)(b) of the Act. There is nothing in the language of this provision to suggest that an institution of mixed objects is precluded from getting registration u/s 12AA of the Act. It is also seen from the objects of the trust in question that the assessee is carrying on no non-charitable or non-religious activities. We place reliance on the judgement of ACIT v. Barkate Saifiyah Society 213 ITR 492 (Guj) and CIT v. Chandra Charitable Trust 294 AITR 86 ( Guj), wherein it was held that a trust can either be for religious purposes or for charitable purposes or it can be for both. Only a trust which is for religious purpose is excluded and debarred from registration u/s 12AA of the Act. A trust whose object is charitable as well as religious is not debarred from registration.