Held that the assessee-society should have been registered under Societies Registration Act, 1860, especially when immovable properties were held by the society. The Commissioner (E) further held that section 5 of the Indian Trusts Act, 1882, says that no trust in relation to immovable property is valid, unless declared by a non-testamentary instrument in writing signed by the author of the trust or the trustee and registered, or by the will of the author of the trust or of the trustee. The provisions of the 1882 Act, though applicable to the private trusts, can be extended to public charitable trusts and also to societies. The assessee had neither registered under the Indian Registration Act, 1908 nor under the Societies Registration Act.  Rejection of exemption was held to be valid.