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5. The learned CIT grossly erred in holding that the appellant trust did not produce donation receipts which is not only incorrect but bordering on false hood since the appellant filed mass of details including the receipts.

6. The learned CIT grossly erred in holding that the trust has twin objects both charitable and hence the trust cannot be allowed the benefit of registration. The activities carried out by the trust are admixture of both religious and charitable

7. The learned CIT erred in rejecting the claim for exemption u/s 80G without passing a speaking order and hence the order is nullity in law.

As decided in the case of The Society of presentation sisters & another, 318 ITR (AT)287(Cochin) by the Cochin bench of the !TAT that overlapping of religious and charitable activity cannot render the object of the Trust as not charitable in nature and cannot be reason for denying exemption u/s 11(1)(a) of the Act or deny registration to the assessee Trust u/s 12AA of the Act.

Allahabad High Court Fifth Generation Education Society vs CIT(1990)185 ITR 634 and of the Madras High court in New life in Christ Evangelist Association Vs CIT 2000 246 ITR 532.

"2. We have heard both parties. In so far as the requisite registration u/s 12AA of the Act by the ld. CIT is concerned, the ld.AR argued that despite the fact that the assessee-trust is created for dong charitable activities, on irrelevant reasons, the ld. CIT has refused to grant registration u/s 12AA of the Act. On the other hand, the ld.DR supported the order of the ld. CIT. We have found that the trust was created on 12.7.2007. A copy of the trust deed was also filed. The objects of the trust are found to be charitable in nature. The ld. CIT has observed that the objects of the trust are mixture of both religious and charitable. The Cochin Bench of the Tribunal in the case of The Society of Presentation Sisters & Another, 318 ITR (AT) 287(Cochin), while dealing with an identical issue, has held that overlapping of religious and charitable activity cannot be taken as a reason to deny exemption u/s 11(1)(a) of the Act, as it cannot render the objects of the trust as not charitable in nature. Consequently, we direct the ld. CIT to grant registration to the assessee-trust u/s 12AA of the Act.