Dismissing the appeal of the revenue the Court held that  Section 11 of the Act deals with the income from the property held for charitable or religious purposes. In Fazlul Rabbi Pradhan v. State of West Bengal AIR 1962 SC 1722 while dealing with the expression charitable purpose and religious purpose  the Supreme Court held that for satisfying the test for charitable purpose, there must always be some element of public benefit. In Ramchandra Shukla v . Shri Mahadeoji  AIR 1970 SC 458 has held that in Hindu system there is no line of demarcation between religion and charity is regarded as part of the religion. In CIT v. Barkate Saiflyah Society   ( 1995) 213 ITR 492  (Guj) (HC)   by placing reliance on aforesaid decisions of the Supreme Court held that the words ‘trust for charitable purpose’ would include even trust for advancement of religion. It may be noted that if the object of the trust is partly religious and partly charitable, so long as no part of income or corpus is utilized for a purpose, which is not either charitable or religious, a trust is entitled to exemption under Section 11(1)(a) of the Act and such a trust is entitled for registration under Section 12AA of the Act.