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Issues: Whether a trust with composite charitable and religious objects, some directed towards a particular religious community and others for the public at large, was entitled to registration under section 12A and whether section 13(1)(b) barred such registration.
Analysis: The objects in the trust deed had to be examined to determine the nature of the trust. The record showed that while certain objects referred to the Christian community, other objects were directed to the public at large, including ambulance facilities and educational and welfare activities for needy and deserving persons in general. The governing principle was that the character of the trust depends on its declared objects, and a trust may be both charitable and religious. Where the trust is not exclusively for the benefit of a specific religious community, section 13(1)(b) does not apply. On that basis, the trust was treated as a charitable religious trust and the Commissioner's view that registration would serve no purpose was not sustained.
Conclusion: Registration under section 12A could not be denied on the ground of section 13(1)(b); the trust was entitled to registration as a charitable religious trust.