Dismissing the appeal of the revenue the Court held that, the certificate of registration is only an enabling provision to claim exemption. Even if the registration is granted, the exemptions from the provisions of the IT Act in particular S. 11 and 12 is not automatic. It is only when the assessee satisfies the requirement of S. 13, he would be eligible for exemption. Accordingly the registration cannot be refused on the ground that the Trust  deed is not having any provision in relation to disbursement of balance funds in the eventuality of the dissolution of Trust.