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10. This amendment was forwarded to the Registrar of the Societies on8-7-2006, for taking it on record and to be returned as duly registered to the association at an early date. On the basis of these facts the Association submitted that the objects of the association were not only for the residents of Greater Kailash-II but also extends to citizens of Delhi in general, or so to say the public in general. Therefore, it can be said that there was an identifiable common quality of a public or impersonal nature and the case of the Association falls in the ken of the Supreme Court decision in the case of Ahmedabad Rana Caste Association's (supra). The learned Counsel also referred to the decision of Allahabad High Court in the case of Fifth Generation Education Society v. CIT , and submitted that merely because the objects of a charitable trust are general and they do not cease to be charitable. Placing reliance on the decision of Madras High Court in the case of New Life Christ Evangelistic Association v. CIT , it is contended that at the time of registration, what is to be seen is that the objects are charitable in nature and the activities are genuine and not on the fact as to how and where its income was going to be spent for. In any case, the Association has developed eight parks, a few of them, are very large, which cater to the needs of the nearby colonies of Chitranjan Park and Alakhnanda as well. It had fifteen thousand members in Greater Kailash - II which by itself is a very large number; the residents become members without any distinction of caste or creed, and therefore, not personal. Facilities are for common good to be enjoyed by all. He referred to certain expenditure on horticulture and Diwali Mela.

21. As held by Allahabad High Court in the case of Fifth Generation Education Society (supra), that merely because the objects of a charitable trust are general and they do not cease to be charitable. Before a person can claim the benefit of Section 11 or Section 12, as the case may be, he must obtain registration under Section 12A. The application for registration under Section 12A has to be made in Form No. 10A prescribed by rule 17A of the Income-tax Rules, 1962, before the expiry of one year from the date of creation of the trust or the establishment of the institution whichever is later. It has to be made by the person in receipt of the income of the trust. At that stage, the Commissioner is not required to examine the application of income. All that he may examine is whether the application is made in accordance with the requirements of Section 12 A read with rule 17A of the Income-tax Rules, 1962, and whether Form No. 10A has been properly filled up. He may also see whether the objects of the trust are charitable or not. Merely, because the objects of a charitable trust are general, they do not cease to be charitable. It is also not for the requirement of Section 12A that any activity should be carried on by the charitable society for obtaining registration.