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1.19. Without prejudice to above, it is submitted that the present Trust is registered under Rajasthan Public Trust Act, 1959 which in itself ensures that it is not a private religious trust.

2. Absence of dissolution clause:

2.1. During the course of hearing before Id. CIT(E) vide letter dated 22.05.2023 at para 25 [PB 9-

10] an undertaking was given to include the dissolution clause. The Trust is in the process of amending its constitution to include dissolution clause ensuring that on dissolution of the Trust all its assets would be transferred only to some other trust having similar objectives. 2.2. Hon'ble ITAT Delhi Bench in the case of Roop V.K Jain Foundation v. CIT(E) in ITA No. 297/Del/2021 has ruled that application for registration under section 12AA of the Income Tax Act, 1961 should not be denied in absence of dissolution clause in trust deed. 2.3. Without prejudice to above, it is submitted that the Trust was settled long back in the year 1964. The Founder of the Trust is no more alive. Trustees also keep on changing in terms of the Trust Deed. Under these circumstances absence of dissolution clause should not result into any adverse inference against the assessee trust.