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3.20 To establish liaison and development mutual areas or cooperation with different organizations international, national, state local whether voluntary or official and with specialized institutions groups and individual associations in furtherance of the aims and objects of the Trust to take steps for eradicating illiteracy and spreading education and hygiene; and 3.21 To carry on such further charitable objects of general public utility as are computable or in consonance with the objects of the Trust.

41. Therefore, the objects of the trust exhibit the dual tenor of religious and charitable purposes and activities. Section 11 of the Act shelters such trust with composite objects to claim exemption from tax as a religious and charitable trust subject to provisions of Section 13. The activities of the trust under such objects would therefore be entitled to exemption accordingly.

49. In the present case, the objects of the respondent-trust are based on religious tenets under Quran according to religious faith of Islam. We have already noticed that the perusal of the objects and purposes of the respondent-trust would clearly demonstrate that the activities of the trust though both charitable and religious are not exclusively meant for a particulars religious community. The objects, as explained in the preceding paragraphs, do not channel the benefits to any community if not the Dawoodi Bohra Community and thus, would not fall under the provisions of Section 13 (1) (b) of the Act.

In support of the same, learned counsel relies upon the decision of a Division Bench of the Andhra Pradesh High Court in the case of Commissioner of Income-Tax vs. Arya Vysya Kalayana Nilaya Sangam : (1986) 159 ITR 324, at pages 328 and 329 of which, it has been held as follows:-

" We are unable to accept the Revenue‟s plea that a new trust has come into existence on December 5, 1967, when registration was made under the Societies Registration Act. It may be pointed out that there is no requirement under the law that a trust should be registered under the Societies Registration Act in order to be recognized as a charitable institution for the purpose of earning exemption under section 11 of the Act. The requirement for earning exemption under Section 11 of the Act is that there must be an institution in existence which may be in the nature of a trust or held under any legal obligation. The will dated October 20, 1918, executed by the Late K. China Venkata Subbaiah had undoubtedly brought into Patna High Court CWJC No.20698 of 2010 dt.23-11-2016 existence a trust for the benefit of the Vysya community. Trustees were duly appointed under the will. Objects were specified and the manner in which the trust fund should be utilized was specified in the will. These requirements are sufficient to render the purpose as coming within the purview of a trust created under the will dated October 20, 1918. There is also a legal obligation imposed under the will to hold the properties for the purposes specified in the will. The Act does not lay down any requirement that in order to be recognized as a public charitable institution, there must be registration under the Societies Registration Act. It is obviously for a collateral purpose that registration has been sought in the present case under the Societies Registration Act and that fact does not militate against the claim that there has been in existence already an institution administered under the will dated October 20, 1918. There is also nothing inconsistent in law in an existing trust augmenting its Patna High Court CWJC No.20698 of 2010 dt.23-11-2016 resources by securing more contributions with the specific purpose of utilizing all such contributions upon the objects specified in the trust already created. Indeed, there is no dispute in the present case that the objects for which the trust was created under the will dated October 20, 1918, or the objects subsequently added by the trustees were charitable in character. The only dispute is that although the objects were charitable in nature, the society having come into existence on December 5, 1967, could be governed by the provisions of section 13 (1) (b) of the Act. As already pointed out, there is already in existence an instrument evidencing the creation of a trust as far back as October 20, 1918, and what had happened on December 5, 1967, was merely registering the same document under the Societies Registration Act. We do not think that the Revenue is right in contending that a new trust came into existence and the provisions of section 13 (1)