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allegation of the Revenue that the assessee trust has not fulfilled the mandatory requirement of admitting the requisite number of OPD and IPD patients in violation of the direction of the Hon'ble Delhi High Court is concerned, the same is also not supported by any evidence. There is nothing on record to suggest that the assessee has refused admission to any person of the economically weaker section nor the Government has taken any action against the assessee for such violation. The argument of the ld. counsel for the assessee that the statistics have always been displayed near the reception giving the list of patients and such copy was also always filed with the Director of Health Services, Government of Delhi and neither any patient has made any complaint nor the Government has taken any action could not be controverted by the ld. DR. Since there is no allegation by the Revenue that the activities of the trust/society are not genuine or are not being carried out in accordance with the objects of the trust and since the ld. counsel for the assessee before us has demonstrated clearly that the management and control of the hospital was always with the assessee society and the assessee society has not virtually handed over the management of the hospital to the Max group of concerns which are corporate bodies established with the clear intention of profit motive and since the Revenue also failed to bring on record any material to suggest that the assessee trust has refused any patient from the economically weaker section of the society in violation of the guidelines laid down by the Hon'ble Delhi High Court, we find no justification on the part of the Ld.DIT(E) for withdrawing the registration granted u/s 12AA of the Act with retrospective effect.

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Section 12AA & 13 of the Income-tax Act, 1961 — Charitable or religious trust — Since there is no allegation by the Revenue that the activities of the trust/society are not genuine or are not being carried out in accordance with the objects of the trust and since the ld. counsel for the assessee has demonstrated clearly that the management and control of the hospital was always with the assessee society and the assessee society has not virtually handed over the management of the hospital to the Max group of concerns which are corporate bodies established with the clear intention of profit motive and since the Revenue also failed to bring on record any material to suggest that the assessee trust has refused any patient from the economically weaker section of the society in violation of the guidelines laid down by the Hon'ble Delhi High Court, there was no justification on the part of the Ld.DIT(E) for withdrawing the registration granted u/s 12AA with retrospective effect, accordingly the order of the DIT(E) was set aside and the registration granted earlier u/s 12A was restored—Devki Devi Foundation vs. Director of Income-tax (Exemptions) [2020] 180 ITD 417 (DEL)

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