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Venu Charitable Society And Anr. Vs. Director General Of Income Tax
March, 16th 2017
*       IN THE HIGH COURT OF DELHI AT NEW DELHI
                                                Reserved on: 01.12.2016
                                              Pronounced on: 08.03.2017
+       W.P.(C) 7147/2012
        VENU CHARITABLE SOCIETY AND ANR.              ..... Petitioners
                        Through: Sh. Ajay Vohra, Sr. Advocate with Ms.
                        Kavita Jha and Sh. Vaibhav Kulkarni, Advocates.

                           Versus

        DIRECTOR GENERAL OF INCOME TAX            ..... Respondent
                      Through: Sh. P. Roychoudhuri with Ms. Vibhooti
                      Malhotra, Advocates.
        CORAM:
        HON'BLE MR. JUSTICE S. RAVINDRA BHAT
        HON'BLE MS. JUSTICE DEEPA SHARMA
MR. JUSTICE S. RAVINDRA BHAT
%
1.   The petitioner is registered under the Societies Registration Act, 1860
and formed with the objective of rendering comprehensive eye care services,
inclusive of all forms of ophthalmic services. To further its objects, it
established the "Venu Eye Institute and Research Centre in Delhi", with five
satellite hospitals and seven vision centers in Haryana, Uttar Pradesh,
Uttarakhand and Rajasthan. Its claim is that its objects, for assessment years
2005-2006to 2009-2010 were charitable in terms of Section 2(15) of the Act.
However, for 2011-2012 its application in Form 56D for grant of exemption
under Section 10(23C)(via) of the Act was rejected by the respondent by its
impugned order, dated 27 April, 2012. It, therefore, seeks quashing of the
order and appropriate consequential directions.
2.      The petitioner, to promote its objectives categorized its patients into
three    -   Charity,   Subsidized   and   Private.   It   argued, before   the




W.P.(C) 7147/2012                                                    Page 1 of 18
respondent/Revenue in its application for exemption, that treatment of the
same quality is provided to all patients and that the fee charged is reasonable
and does not involve any profit element. Its objects and activities were,
therefore, wholly philanthropic and for the benefit of the public at large. The
petitioner argued that the expression, "not for purposes of profit" under
Section10 (23C) cannot mean that a hospital or institution cannot or should
not charge any fees from its patients. It only means that one cannot reap
profits on commercial lines. It is submitted that philanthropy not only means
free treatment but also means concessional treatment and the petitioner
charges a nominal fee from the patients to cover running expenses of the
hospital. It was also stated that the petitioner imparts training, which too is a
charitable object, covered by its memorandum and that the fees and charges
recovered by it are entirely reasonable, aimed at meeting the expenses for
such activity.
3.     The Director General of Income Tax (DGIT) for exemption by the
impugned order, noticed that the petitioner had not applied for exemption in
the immediately preceding two years. The impugned order then went on to
analyze the nature of the charges recovered by the petitioner from its patients
and concluded that,
       "From the above chart it is seen that the so called subsidized
       rates charged by the applicant forms almost 42% to 100% of
       the private charges which clearly shows that the same is
       beyond the reach of poor people, and cannot be termed as
       charity as envisaged in. sec. 2(15) of the I.T. Act,
       1961.Although the society is also having the facility of free
       treatment to the patients on the basis of payment of one time
       normal charges, however it is also not disputed; that the
       treatment are provided to the patients on payment basis which




W.P.(C) 7147/2012                                                      Page 2 of 18
       itself proved that the, society is existing not solely for
       philanthropic purposes but for the purposes of profit."

The provision of medical services in the satellite centres was also viewed as
a profit driven motive:
       "6. It is seen that the applicant society is running a base
       hospital at Delhi and 5 satellite hospitals. On 14/03/2011 the
       applicant society has made a collaboration agreement with
       Sant Bhagat Singhji Maharaj Charitable Hospital with regard
       to satellite hospital at Faridabad. The society has also made
       collaboration agreement with Om Indu Jain Charitable Trust
       with regard to satellite hospital at Dhankot. As per the terms
       and conditions of the agreement with Om Indu Jain Charitable
       Trust the applicant society had to invest Rs. 10 lakh for
       construction of the ground floor of the premise at Dhankot and
       had to provide complete infrastructure facilities for
       establishment of an eye hospital including equipment and other
       resources including man power. The period of both these
       agreements was 20 years. One of the conditions in these
       agreements is that the applicant society can also treat the
       patients at these satellite hospitals on payment basis. The
       inclusion of this clause itself proved the profit motive of the
       applicant society."

4.     The DGIT then discussed the teaching and training aspect of the
petitioner's activities and after noticing the fees charged as well as the
facilities provided (on the basis of what was listed in the petitioner's website
as well as the details provided by it) held as follows:
       "11. From the above it is clear that the applicant society
       besides running the Hospital and doing charitable activity is
       also engaged in imparting educational training on regular
       basis for which various facilities are provided to the students
       and fee is charged. Although, education may be a good activity
       but this is not in consonance with the provisions of section
       10(23C)(via) of the IT Act, 1961. Further, the society has









W.P.(C) 7147/2012                                                     Page 3 of 18
       categorized their patients in 3categories viz.- (i) Charity
       patients (ii) Subsidized patients and (iii) Private patients which
       show that besides charity the society is also working on
       commercial lines. The society has made collaboration
       agreements with other Trusts and one of the conditions made in
       the agreements is that the eye centre of the society running from
       the premise of other Trusts can also treat the patients on
       payment basis which proves that the society is also running on
       commercial lines. All these facts clearly prove that the
       applicant society is existing not solely for philanthropic
       purposes but existing for purposes of profit also as against the
       spirit of the provisions of section 10(23C)(via) of the Income
       Tax Act, 1961."

5.     The petitioner argues that as a charitable activity, it is not expected to
completely eschew profits or surpluses. It urges that what the Revenue has to
examine is if the objects upon which a trust or society seeks exemption fall
within the scope of the definition under Section 2 (15). It relies on the
decision in Commissioner of Income Tax v. Pulikkal Medical Foundation (P)
Ltd. [1994] 210 ITR 299 (Ker) where it was held that:-
       "...merely because the assessee is running the hospital on
       commercial lines, it will not be disentitled to the exemption
       under section 10(22A) of the Act. As long as the dominant
       purpose is a philanthropic one, the mere circumstance that the
       managing director or director gets some advantages or
       exercises some patronage while running the institution, that
       will not be a ground to hold that the main purpose of the
       institution is not philanthropic."

6.     Likewise the decision of the Bombay High Court in Breach Candy
Hospital Trust v. Chief CIT, ITO and UOI[2010] 322 ITR 246 (Bom) is
relied on. It was held that there may be surplus in some areas and deficit in
others. It further stated:




W.P.(C) 7147/2012                                                      Page 4 of 18
       "A hospital has many units and ultimately all receipts are used
       for treatment. In the absence of any material to show that
       generally there was a profit, it cannot be said that the petitioner
       does not exist solely for the philanthropic purpose but exists for
       the purpose of profit."

7.     It is pointed out that the petitioner society was also granted exemption
under Section 80G and 35AC of the Act and the Assessing Officer (AO) for
the years 2005-06 to 2009-10 held its activities to fall within the purview of
Section 2(15) of the Act, i.e., charitable purpose. It is contended that the
satellite hospitals run by the petitioner have no profit element in them. The
petitioner entered into an arrangement with the Indira Gandhi National Open
University (IGNOU) to provide training courses for para-medicals and
nursing staff. IGNOU charges a fee of which a nominal amount is given to
the petitioner. This activity is incidental and in furtherance of achieving the
main objective. Again, there is no profit element involved and the
expenditure incurred is way more than the amount collected by way of fees.
The petitioner points out that it has other objectives too, but the presence of
incidental objectives in the memorandum does not preclude it from claiming
exemption under Section 10 (23C) of the Act. For this point, it relies on
Baun Foundation Trust v. CCIT &Anr(2012) 251 CTR (Bom.) 237 in which
it was held that one has to consider whether the overall object is to make
profit. If after meeting the expenditure any surplus results incidentally from
the activity lawfully carried on by the institution, it will not cease to be one
existing solely for the statutorily stipulated purpose so long as the object is
not to make a profit. The dominant nature of the purpose has to be
considered.




W.P.(C) 7147/2012                                                      Page 5 of 18
It is argued that the petitioner had claimed exemption under Section 11 and
therefore omitted to claim exemption under Section 10 (23C) for AYs 2007-
08 to 2009-10.

8.      Counsel for the Revenue relies on the order denying exemption and
submits that during the proceedings under Section10(23C)(via), information
was obtained from the petitioner's website which was reproduced in the
impugned order. These details clearly indicated that the petitioner is also
engaged in the field of imparting education and training for which it charges
fee. Even separate training programmes for foreign students are provided for
a fee. These foreign students are also provided hostel and other facilities on a
paid basis. Furthermore, fees for various courses are paid to the petitioner
society. All these belie the petitioner's submission that the students pay their
fees to IGNOU and a nominal amount is given by IGNOU to it.
9.     The Revenue argues that during the AY 2008-09 to 2010-11 the
receipts of the petitioner under the head Training & Tuition fees was
`39,51,657/-and `44,90,276/- which further prove that the organization
exists not solely for philanthropic purposes but for purposes of profit too.
The petitioner society was notified under Section 10(23C)(via) for AY
2004-05 to 2006-07. It, however did not file any application for renewal of
notification for AY 2007-08 to 2010-11. However, on perusal of the return
of income for the AY 2009-10 it was seen that the petitioner had claimed
income amounting to `19,85,337/- to be exempt u/s 10(23C)(vi) of the
Income Tax Act, 1961. Further, during the AY 2008-09 the petitioner itself
accepted the activity of the hospital including Vision by Venu as deemed
business and has shown the net profit/loss for hospital activity and Vision by




W.P.(C) 7147/2012                                                     Page 6 of 18
Venu amounting to `89,06,243/ and (-) `14,91,647/- respectively. All these,
according to the Revenue, clearly show that the petitioner is engaged in
business activities.
10.      The Revenue highlights that the petitioner claimed exemption under
Section 11 in respect of part of its income, i.e., Grants and in respect of
income/receipts from Hospital and Vision by Venu it claimed the benefit of
exemption under Section 10(23C)(vi) during the same year. It was also seen
that in respect of grants, it claimed the benefit of accumulation or set apart
for future use under Section 11(2) of the Income Tax Act, 1961. The
petitioner did not have the exemption under Section 10(23C)(vi) in AY
2008-09 to 2010-11 but it claimed that under Section 10(23C)(vi) for these
years.
11.      From these facts, submitted the Revenue, it is clear that besides
running the hospital and doing charitable activity, the petitioner was also
engaged in imparting education/training on regular basis. It provided various
facilities to the students and charged fees. Although, education may be a
charitable activity yet that is not in consonance with the petitioner's objective
to attract the provisions of Section 10(23).Also, the society categorized their
patients into three, i.e.(1) Charity patients (2) Subsidized patients and(iii)
Private patients which show that besides charity it works on commercial
lines. The society has made collaboration agreements with other Trusts and
one of the conditions in those agreements is that the eye centres in the said
third parties' premises can also treat the patients on payment basis, which
proves that the petitioner functions on commercial lines. All these facts
clearly prove that the petitioner does not exist solely for philanthropic
purposes but for profit purposes too, contrary to the provisions of Section




W.P.(C) 7147/2012                                                      Page 7 of 18
10(23C)(via) of the Income Tax Act,1961. Therefore application of the
petitioner society for notification under Section 10(23C)(via) for the AY
2011-12 and onwards was correctly rejected by the respondent.


Analysis and Findings

12.    The record reveals that the petitioner was registered under Section 12A
of the Act by order dated 16.11.1987 passed by the CIT and it also obtained
approval under Section 80G of the Act, after satisfying the conditions
prescribed. It was also notified for exemption under Section 35AC of the Act
by the National Committee for Promotion of Social and Economic Welfare.
The petitioner was notified under Section 10(23C)(via) of the Act for AYs
2005-06 to 2007-08. However, it filed no application for renewal of
exemption for AYs 2008-09 to 2010-11.
13.    In the return of income filed for those years, the petitioner claimed
exemption under Section 11 of the Act in respect of income earned and
applied for charitable purposes. The AO while completing the assessment for
assessment years 2005-06 to 2009-10,held that the activities of the Society
fell within the ambit of Section 2(15) of the Act, i.e., charitable purpose. It
thereafter applied through Form 56D for grant of exemption under Section
10(23C)(via) of the Act for assessment years 2011-12 onwards. In support of
its claim for exemption, the petitioner filed the following documents:
(i) Details of patients treated for free by Venu Eye Institute &Research
Centre during the period October 2008 to March2010 as per the report
submitted with Directorate of Health Services.
(ii) Quarterly details of patients treated free (in accordance with the terms




W.P.(C) 7147/2012                                                    Page 8 of 18
and conditions of allotment of land) during the period April, 2007 to March,
2010.
(iii) Copies of Annual Activity Reports for the period April, 2005to March,
2011 containing details and report on activities carried out by the Society.
(iv) Newspaper cutting from the Times of India dated 24.09.2009, containing
report on survey by Health Department which clearly mentioned that the
hospital run by the petitioner society was the only hospital with maximum
occupancy of free beds (63 beds) against the quota of 42 beds specified by
the Delhi Government.
14.     The respondents rejected the exemption application by order dated
27.4.2012 under Section 10(23C)(via) of the Act, inter alia, on the grounds
that firstly, the petitioner did not exist solely for philanthropic purposes but
for purpose of profit; secondly, it had entered into collaboration agreements
with Sant Bhagat Singhji Maharaj Charitable Hospital and Om Indu Jain
Charitable Trust for running satellite hospitals with profit motive; thirdly,
that it provided educational courses such as Medical Training Programmes,
long term super specialty medical programme in ophthalmology, etc. and
was earning profit from those activities; fourthly, the memorandum of the
petitioner society contains objects other than health care; and lastly that it
made no application for renewal of exemption under Section10(23C)(via) for
AY 2007-08 to 2010-11.
15.     The provision, i.e. Section 10(23)(vi) reads as follows:
        "10. Incomes not included in total income.- In computing the
        total income of a previous year of any person, any income
        falling within any of the following clauses shall not be included
        --
        (23C) any income received by any person on behalf of-




W.P.(C) 7147/2012                                                     Page 9 of 18
       (vi) any university or other educational institution existing
       solely for educational purposes and not for purposes of profit,
       other than those mentioned in sub-clause (iiiab) or sub-clause
       (iiiad) and which may be approved by the prescribed authority;
       or Provided that the fund or trust or institution or any
       university or other educational institution or any hospital or
       other medical institution referred to in sub- clause (iv) or sub-
       clause (v) or sub-clause (vi) or sub- clause (via) shall make an
       application in the prescribed form and manner to the
       prescribed authority for the purpose of grant of the exemption,
       or continuance thereof, under sub-clause (iv) or sub-clause (v)
       or sub- clause (vi) or sub-clause (via):

       Provided further that the Central Government, before notifying
       the fund or trust or institution, or the prescribed authority,
       before approving any university or other educational institution
       or any hospital or other medical institution, under sub-clause
       (iv) or sub-clause(v) or sub-clause (vi) or sub-clause (via), may
       call for such documents (including audited annual accounts) or
       information from the fund or trust or institution or any
       university or other educational institution or any hospital or
       other medical institution, as the case may be, as it thinks
       necessary in order to satisfy itself about the genuineness of the
       activities of the fund or trust or institution or any university or
       other educational institution or any hospital or other medical
       institution, as the case may be, and the Central Government or
       the prescribed authority, as the case may be, may also make
       such inquiries as it deems necessary in this behalf:

       Provided also that the fund or trust or institution or any
       university or other educational institution or any hospital or
       other medical institution referred to in sub- clause (iv) or sub-
       clause (v) or sub-clause (vi) or sub- clause (via)-

       [(a) applies its income, or accumulates it for application,
       wholly and exclusively to the objects for which it is established
       and in a case where more than twenty-five per cent of its




W.P.(C) 7147/2012                                                     Page 10 of 18
       income is accumulated on or after the 1st day of April, 2001,
       the period of the accumulation of the amount exceeding twenty-
       five per cent of its income shall in no case exceed five years;
       and]

Section 10 (22) exempts receipts and income of universities and educational
institutions, in the following terms:

       "(22) any income of a university or other educational
       institution, existing solely for educational purposes and not for
       purposes of profit."

16.    ACIT v. Surat Art Silk Cloth Manufacturers Association (1980) 121
ITR 1 (SC) held that the test of predominant object of the activity is to be
seen to determine whether it exists solely for education and not to earn
profit. However, the purpose would not lose its character merely because
some profit arises from the activity. To carry on educational activity in such
a way that the expenditure exactly balances the income and there is no
resultant profit, would not only be difficult for practical realization, but
would reflect unsound principles of management. In order to ascertain
whether the Institute is carried on with the object of making profit or not, it
is the duty of the prescribed authority to ascertain whether the balance of
income is applied wholly and exclusively to the objects for which the
applicant is established. The decisions of the Supreme Court in Queens
Educational Society v Commissioner of Income Tax (2015)] 372 (ITR) 699
(SC); Indian Chamber of Commerce v Commissioner of Income Tax (1975)
101 ITR 796 (SC); Aditanar Educational Society v Commissioner of Income
Tax (1997) 224 ITR 310 (SC)and Oxford University Press v CIT (2001) 247
ITR 658 (SC) also talk of the predominant purpose test as determinative of




W.P.(C) 7147/2012                                                   Page 11 of 18
whether an assessee existed solely for educational purposes.
17.    Section 10 (23C) of the Act exempts any hospital or other institution
for treatment of illness or mental deficiencies or treatment during
convalescence requiring medical attention or rehabilitation solely for
philanthropic purposes and not for purposes of profit. If the government does
not fund it, then, its annual receipts should not exceed the prescribed limit.
Section 2 (15) defines "Charitable Purpose" and includes the following - i)
Relief of the poor; ii) Education; iii) Medical relief and iv) advancement of
any other object of general public utility. An entity with such a purpose is
eligible for exemption from tax under Section 11 or alternatively under
Section 10 (23C) of the Act. There was a proviso inserted in 2008 which
prescribed that "Advancement of any other object of general public utility
shall not be a charitable purpose if it involves the carrying on of- a) any
activity in the nature of trade, commerce or business; b) any activity of
rendering any service in relation to trade, commerce or business; for a cess
or fee or any other consideration." However, this proviso was inapplicable
to the first three limbs of the Section 2 (15) and they continue constitute a
charitable purpose even if incidentally involved the carrying on of
commercial activities.

18.    The incidental carrying on of commercial activities is subject to
certain conditions stipulated under the seventh proviso to Section 10 (23C).
They are- (a) The business should be incidental to the attainment of the
objectives of the entity and (b) Separate books of account should be
maintained in respect of such business. The memorandum of the petitioner's
society clearly states its main objective is to render comprehensive eye care




W.P.(C) 7147/2012                                                  Page 12 of 18
services inclusive of all forms of ophthalmic services. All other activities are
incidental to carrying out of this purpose. The petitioner does not carry out
any other business but only collaborates with other trusts and institutions. It
has maintained its books of account as well. So the conditions have been met
with. Exemption under the provisions mentioned above will be granted if the
main objective of the society is relief of poor, education, medical relief and
carrying on of a business with a view to fulfill these objects would not
deprive them from such exemption. This was stated in CIT v. Rao Charitable
Trust (1976) 102 ITR 474.

19.     As to the Revenue's contention that the petitioner's collaboration with
other institutions and for profit goes, clearly the dominant object or purpose
test is applicable. In New Noble Educational Society & Ors. Vs. Chief
Commissioner of Income tax &Anr. (2011) 334 ITR 303 (AP)it was held that
if there are several objects of a society some of which relate to education,
and others which do not, and the trustees or the managers, in their discretion,
are entitled to apply the income or property to any of those objects, the
institution would not be eligible to be regarded as one existing solely for
educational purposes, and no part of its income would be exempt from tax.
But if the primary or dominant purpose of an institution is "educational",
another object, which is merely ancillary or incidental to the primary or
dominant purpose, would not dis-entitle the institution from the benefit. In
American Hotel and Lodging Association Educational Institute vs.
CBDT [2008]301 ITR 86(SC), the Supreme Court held that at the time of
granting approval under Section 10(23C)(vi), the prescribed authority is to
be satisfied that the institution existed during the relevant year solely for




W.P.(C) 7147/2012                                                    Page 13 of 18
educational purposes and not for profit. Once the prescribed authority is
satisfied about fulfillment of this criteria i.e., the threshold precondition of
actual existence of an educational institution under Section10 (23C)(vi), it
would not be justifiable, in denying approval on other grounds.

20.    The Revenue's other contention was that the petitioner had applied for
exemption under Section 11 as well as Section 10(23C) in the same year.
Section 10(23C) does not prescribe any stipulation, which makes registration
u/s 12AA a mandatory condition. The provisions of Section 11 and 10(23C)
are two parallel regimes and operate independently in their respective
realms. In order to avail exemption u/s 11, 12 and 13, the entity should be
registered u/s 12AA. The Sections 11, 12, 12A, 12AA and 13 of the Income
Tax Act constitute a complete code governing the grant, cancellation or
withdrawal of registration, providing exemption to income, and also the
conditions subject to which a charitable trust or institution is required to
function in order to be eligible for exemption. The primary objective of
providing exemption in case of charitable institution is that income derived
from the property held under trust should be applied and utilized for the
object or purpose for which the institution or trust has been established. In
many cases it had been noted that trusts or institutions, which are registered
and have been availing benefits of the exemption regime do not apply their
income, which is derived from property held under trust, for charitable
purposes. In such circumstances, when the income becomes taxable, a claim
of exemption under general provisions of Section 10 in respect of such
income is preferred and tax on such income is avoided. This defeats the very
objective and purpose of placing the conditions of application of income etc.









W.P.(C) 7147/2012                                                    Page 14 of 18
in respect of income derived from property held under trust in the first place.
The provision of Section 10(23C) also has similar conditions of
accumulation and application of income, investment of funds in prescribed
modes etc. Therefore, the Act was amended to provide specifically that
where a trust or an institution has been granted registration for purposes of
availing exemption under Section 11, and the registration is in force for a
previous year, then such trust or institution cannot claim any exemption
under any provision of Section 10 [other than that relating to exemption of
agricultural income and income exempt under Section 10(23C)] of the
Income Tax Act. Similarly, entities which have been approved or notified for
claiming benefit of exemption under Section 10(23C) of the Income Tax Act
would not be entitled to claim any benefit of exemption under other
provisions of Section 10 of the Act; which means that one can claim
exemption under Section 11 and Section 10 (23C).

21.    Coming back to what a charitable purpose is, an educational institution
may qualify for relief under Section 10 (23C) of the Act, as well as, Section
11. In the present case, the petitioner provides training courses to students
and nursing staff, which qualify for exemption. The main objective of the
program must be the availability of such a training to the public at large and
imparting some kind of knowledge through it. The fact that some of the
beneficiaries pay for the benefits they get from the institution would not be
fatal to the charitable character of the institution. Accordingly, where an
association, which was in charge of a nursing home and hospital, charged its
patients for the services rendered, it was held it would not cease to be
charitable. In IRC v. Peebleshire Nursing Assn 11 TC 335, it was held that




W.P.(C) 7147/2012                                                   Page 15 of 18
where a hospital runs a private ward where patients pay in full for the
services rendered to them, it would not make the hospital inconsistent with
its charitable objects. Likewise, the petitioner's providing medical facilities
on wholly charitable, or partly subsidized basis to some patients and
charging others at rates par with other institutions per se cannot debar it from
the benefit of being treated as charitable. The dominant purpose test
presupposes that as long as the activity answers the description of charity
and conforms to the objects of the trust or society, that profits or surpluses
are generated, incidentally cannot rob it of the benefits. If the profits from
business feed charitable objects, then it is not an activity for profit, so the
exemption need not be lost. Therefore, total charity to some poor and
deserving patients, partial subsidization of some others and charging of full
rates from some, does not rob the essential and dominant object of the
society, i.e. medical service and education. Indeed, in the case of medical
facilities, a nuanced subsidization through a cross subsidization scheme (i.e.
charging market rates from some and subsidizing some entirely and a few
partly) would fit with the purpose of the petitioner society, which might be
able to thus provide greater service to a larger number of people. It renders
its existence economically viable and expands its reach and scope.

22.    In Director of Income Tax v. All India Personality Enhancement &
Cultural Centre for Scholars Aipeccs Society[2015] 281 CTR (Del) 1 it was
held that insofar as the question whether the university or educational
institution exists solely for educational purposes could be denied the benefit
of Section 10(22)/10(23C) (vi) on the ground that its receipts exceeded its
expenditure is concerned, such question is no longer relevant. It is now well




W.P.(C) 7147/2012                                                    Page 16 of 18
established that an educational institution existing solely for educational
purposes would not cease to be so only for the reason that some of its
activities have yielded surpluses. In the present case, it is observed that profit
earned is incidental to the main objective of charity. It earns profit after
carrying out activities which are to achieve the main purpose. Hence, the
petitioner should be entitled to the exemption. Queen's Educational Society
(supra) summarized the law on the issue as under:--

       1)     "Where an educational institution carries on the activity
       of education primarily for educating persons, the fact that it
       makes a surplus does not lead to the conclusion that it ceases to
       exist solely for educational purposes and becomes an institution
       for the purpose of making profit.
       2)     The predominant object test must be applied - the
       purpose of education should not be submerged by a profit
       making motive.
       3)     A distinction must be drawn between the making of a
       surplus and an institution being carried on "for profit". No
       inference arises that merely because imparting education
       results in making a profit; it becomes an activity for profit.
       4)     If after meeting expenditure, a surplus arises incidentally
       from the activity carried on by the educational institution, it
       will not be cease to be one existing solely for educational
       purposes.
       5)     The ultimate test is whether on an overall view of the
       matter in the concerned assessment year the object is to make
       profit as opposed to educating persons."

23.    In the facts of the present case, it is seen that the objects of the
assessee society are solely for the purposes of education and medical care
and not for purpose of profit. It is only if it is found that the assessee has
been carrying on its activities for the purposes of profit, contrary to its
objects, the prescribed authority would be justified in rejecting the




W.P.(C) 7147/2012                                                      Page 17 of 18
application for approval under Section 10(23C)(vi) of the Act. Merely
because it charges fees for educational courses (as in the case of any school
or college) or that it entered into arrangements with other institutions (again
charitable) to set up satellite centers, to give medical treatment, or that its
treatment involves a layered subsidization programme, would not justify
rejection of its application. For these reasons, the impugned order, denying
exemption under Section 10(23) was not justified; the order dated 27
April,2012 is hereby quashed. The Revenue is directed to consider the
petitioner's application, process it and pass necessary orders in accordance
with law, within four weeks from today. The writ petition is allowed in these
terms.


                                                      S. RAVINDRA BHAT
                                                                (JUDGE)


                                                          DEEPA SHARMA
                                                                 (JUDGE)
MARCH 08, 2017




W.P.(C) 7147/2012                                                   Page 18 of 18

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  face="arial" color="#574200">Daily news and information update for CA members, students and professionals.
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  face="Trebuchet MS" size="2">Hi there,
Greetings of the day!
   
 
  width=100%border=0cellspacing=2cellpadding=2>
 
 
   
  href='http://www.cainindia.org/news/3_2017/reconstitution_of_group_for_rohini_land_at_delhi.html?tstst=58ca57c3442e7&ntitle=Reconstitution of Group for Rohini Land at Delhi' style='text-decoration:none'>
  face='arial' color='#15c' size=2>Reconstitution of Group for Rohini Land at Delhi
 
face='arial' color='#333333' size='2'>
   
   
   
   
   
   
   
  No.M-626/2017
  15th March, 2017
   
   
   
   
   
   
  ALL MEMBERS OF THE COUNCIL
   
   
   
  Madam/Dear Sir,The President, in terms of the authority given to him by the Council at its 363rd meeting held on 12th February, 2017, has reconstituted the Group for Rohini Land (Area 0.526 acre), with the following composition:-
   
  CA. Naveen N.D. Gupta,...

style
='border:1px solid #cccccc;'>
   
  href='http://www.cainindia.org/news/3_2017/invitation_for_contributions_to_question_bank_in_respect_of_information_system_auditassessment_test_isaat_new_syllabus.html?tstst=58ca57c3442e7&ntitle=Invitation for contributions to Question Bank in respect of Information System Audit-(Assessment Test (ISA-AT) (New Syllabus)' style='text-decoration:none'>
  face='arial' color='#15c' size=2>Invitation for contributions to Question Bank in respect of Information System Audit-(Assessment Test (ISA-AT) (New Syllabus)
 
face='arial' color='#333333' size='2'> Announcement
   
  15th March 2017
   
  Invitation for contributions to Question Bank in respect of Information System
  Audit-(Assessment Test (ISA-AT)(New Syllabus)
   
  Information Systems Audit is a post qualification course meant fo...

style
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  href='http://www.cainindia.org/news/3_2017/inviting_expression_of_interest_from_eligible_firms_of_chartered_accountants.html?tstst=58ca57c3442e7&ntitle=Inviting expression of interest from eligible Firms of Chartered Accountants' style='text-decoration:none'>
  face='arial' color='#15c' size=2>Inviting expression of interest from eligible Firms of Chartered Accountants
 
face='arial' color='#333333' size='2'> Inviting expression of interest from eligible Firms of Chartered Accountants
   
  ICAI Accounting Research Foundation (ICAI ARF) established by the Institute of Chartered
  Accountants of India in January, 1999, as a Section 25 Company under the Companies Act, 1956
  (now a Section 8 Company under the Companies Act, ...

style
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  href='http://www.cainindia.org/news/3_2017/monitor_tax_collection_to_meet_target_by_mar_31_cbdt_to_taxman_.html?tstst=58ca57c3442e7&ntitle=Monitor tax collection to meet target by Mar 31: CBDT to taxman ' style='text-decoration:none'>
  face='arial' color='#15c' size=2>Monitor tax collection to meet target by Mar 31: CBDT to taxman
 
face='arial' color='#333333' size='2'>The CBDT has directed the Income Tax department to "scrupulously" monitor tax collection, which it said is slightly less than the target even as the current financial year is nearing an end.
  Central Board of Direct Taxes Chairman Sushil Chandra has dispatched an urgent communication to his regional chiefs, asking them to personally monitor the rev...

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='border:1px solid #cccccc;'>
   
  href='http://www.cainindia.org/news/3_2017/cbdt_to_hold_review_meeting_on_pmgky_tax_collection_on_mar_17.html?tstst=58ca57c3442e7&ntitle=CBDT to hold review meeting on PMGKY, tax collection on Mar 17' style='text-decoration:none'>
  face='arial' color='#15c' size=2>CBDT to hold review meeting on PMGKY, tax collection on Mar 17
 
face='arial' color='#333333' size='2'>Officials said the Central Board of Direct Taxes (CBDT), the policy-making body of the Income Tax Department, will hold the meeting with all the regional heads of the department on March 17.
  The CBDT will hold a high-level meeting later this week to review the progress in collections under the black money window of Pradhan Mantri Garib Kalyan Yojn...

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  href='http://www.cainindia.org/news/3_2017/rbi_to_conduct_overnight_7_day_and_14_day_variable_rate_reverse_repo_auctions_under_laf_on_march_16_2017.html?tstst=58ca57c3442e7&ntitle=RBI to conduct Overnight, 7 day and 14 day Variable rate Reverse Repo auctions under LAF on March 16, 2017' style='text-decoration:none'>
  face='arial' color='#15c' size=2>RBI to conduct Overnight, 7 day and 14 day Variable rate Reverse Repo auctions under LAF on March 16, 2017
 
face='arial' color='#333333' size='2'>The Reserve Bank of India will conduct the following Variable rate Reverse Repo auctions on March 16, 2017, Thursday, as per the revised guidelines on Term Repo Auctions issued on February 13, 2014.
   
   
   
   
  Sl. No.
  Notified Amount( billion)
  Tenor(day)
  Window Timing
  Date of Reversal
   
   
  1
  300
  1
  9.30 am to 10.00 am
  March 17, 2017 (F...

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='border:1px solid #cccccc;'>
   
  href='http://www.cainindia.org/news/3_2017/seminar_on_balance_sheet_in_post_demonetization_and_recent_amendments_in_income_tax_act.html?tstst=58ca57c3442e7&ntitle=Seminar on Balance Sheet in post demonetization and recent amendments in Income Tax Act' style='text-decoration:none'>
  face='arial' color='#15c' size=2>Seminar on Balance Sheet in post demonetization and recent amendments in Income Tax Act
 
face='arial' color='#333333' size='2'>
   
   
   
   
   
   
   
   
   
  Seminar on Balance Sheet in post demonetization and recent amendments in Income Tax Act (OTHERS)
   
   
  Date:
  From: 17-03-2017 – To: 17-03-2017
   
   
  POU Name:
  FARIDABAD BRANCH OF NIRC
   
   
  Event Venue:
  ICAI BHAWAN, 43, SECTOR-20A, FARIDABAD
   
   
  City:
  FARIDABAD
   
   
  CPE Hrs:
  3
   
   
  Venue Capacity:
  450
   
   
  Joint Semina...

style
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  href='http://www.cainindia.org/news/3_2017/_bank_branch_audit_and_benami_transactions_prohibition_amendment_act_2016_pmgky_2016_accounting_and_auditing.html?tstst=58ca57c3442e7&ntitle= Bank Branch Audit And Benami Transactions (Prohibition) Amendment Act, 2016 & Pmgky 2016 Accounting And Auditing' style='text-decoration:none'>
  face='arial' color='#15c' size=2> Bank Branch Audit And Benami Transactions (Prohibition) Amendment Act, 2016 & Pmgky 2016 Accounting And Auditing
 
face='arial' color='#333333' size='2'>
   
   
   
   
   
   
   
   
   
  Bank Branch Audit AND Benami Transactions (Prohibition) Amendment Act, 2016 & PMGKY 2016 (ACCOUNTING AND AUDITING)
   
   
  Date:
  From: 20-03-2017 – To: 20-03-2017
   
   
  POU Name:
  PATIALA BRANCH OF NIRC
   
   
  Event Venue:
  Hotel Polo Club, Near Polo Ground, Opposite Amar Ashram, Lower Mall Road, Patiala – 147001
   
  ...

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  href='http://www.cainindia.org/news/3_2017/income_tax_appellate_tribunal_kolkata_benches_kolkata_consolidated_list_of_order_ready_for_pronouncement_on_150317.html?tstst=58ca57c3442e7&ntitle=Income Tax Appellate Tribunal, Kolkata Benches : Kolkata Consolidated list of order ready for Pronouncement on 15.03.17' style='text-decoration:none'>
  face='arial' color='#15c' size=2>Income Tax Appellate Tribunal, Kolkata Benches : Kolkata Consolidated list of order ready for Pronouncement on 15.03.17
 
face='arial' color='#333333' size='2'>Income Tax Appellate Tribunal, Kolkata  Benches : Kolkata Consolidated list of order ready for Pronouncement on 15.03.17
   
  For more information...

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='border:1px solid #cccccc;'>
   
  href='http://www.cainindia.org/news/3_2017/income_tax_appellate_tribunal_delhi_benches_new_delhi_stay_list_dated_150317.html?tstst=58ca57c3442e7&ntitle=Income Tax Appellate Tribunal, Delhi Benches : New Delhi stay list dated 15.03.17' style='text-decoration:none'>
  face='arial' color='#15c' size=2>Income Tax Appellate Tribunal, Delhi Benches : New Delhi stay list dated 15.03.17
 
face='arial' color='#333333' size='2'>Income Tax Appellate Tribunal, Delhi Benches : New Delhi   stay list dated  15.03.17
   
  For more information...

style
='border:1px solid #cccccc;'>
   
  href='http://www.cainindia.org/news/3_2017/cag_questions_income_tax_deparments_ability_to_probe_shell_companies.html?tstst=58ca57c3442e7&ntitle=CAG questions income tax deparment’s ability to probe shell companies' style='text-decoration:none'>
  face='arial' color='#15c' size=2>CAG questions income tax deparment’s ability to probe shell companies
 
face='arial' color='#333333' size='2'>Although the government has repeatedly vowed to prosecute shell companies for their role in money laundering, especially during the demonetisation period, the audit report prepared by the comptroller and auditor general (CAG) for FY 16 paints a bleak picture of the income tax department’s (ITD) ability to investigate and bring to book these c...

style
='border:1px solid #cccccc;'>
   
  href='http://www.cainindia.org/news/3_2017/tax_optimizer_how_salaried_verma_can_cut_tax_outgo_by_53.html?tstst=58ca57c3442e7&ntitle=Tax Optimizer: How salaried Verma can cut tax outgo by 53%' style='text-decoration:none'>
  face='arial' color='#15c' size=2>Tax Optimizer: How salaried Verma can cut tax outgo by 53%
 
face='arial' color='#333333' size='2'>Taxspanner.com advises readers on how to restructure their income, investments and expenses to optimise their tax.
  Ravi Verma has a very tax friendly income structure. Barely 3.5% of his income goes in tax.
  However, Taxspanner estimates that he can reduce this further to less than 2% of his gross income if his company offers him more tax-free per...

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  href='http://www.cainindia.org/news/3_2017/frequently_asked_questions_on_tax_saving_.html?tstst=58ca57c3442e7&ntitle=Frequently asked questions on tax saving ' style='text-decoration:none'>
  face='arial' color='#15c' size=2>Frequently asked questions on tax saving
 
face='arial' color='#333333' size='2'>Why do I need to provide my landlord's PAN number to my employer to avail deduction of House Rent Allowance (HRA) from gross total income?
  There is no need to provide your landlord's PAN number to your employer if you are paying rent less than Rs. 1 Lakh per year. However, it is mandatory to provide the PAN number of your landlord to your employer...

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  href='http://www.cainindia.org/news/3_2017/all_about_dividend_distribution_tax.html?tstst=58ca57c3442e7&ntitle=All about dividend distribution tax' style='text-decoration:none'>
  face='arial' color='#15c' size=2>All about dividend distribution tax
 
face='arial' color='#333333' size='2'>In India, domestic companies pay Dividend Distribution Tax, or DDT, which is a levy in addition to income tax chargeable on their total income in an assessment year. Here’s what it means:
  1. What is a dividend? A dividend is a return given by a company to its shareholders out of profits made by it during a particular year. They are usually g...

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='border:1px solid #cccccc;'>
   
  href='http://www.cainindia.org/news/3_2017/foreign_investors_may_take_a_refreshed_stance_on_india_investments_after_election_results.html?tstst=58ca57c3442e7&ntitle=Foreign investors may take a refreshed stance on India investments after election results' style='text-decoration:none'>
  face='arial' color='#15c' size=2>Foreign investors may take a refreshed stance on India investments after election results
 
face='arial' color='#333333' size='2'>Many foreign investors that were sitting on the fences may soon take a relook at their India investment strategy following the recent election results where the ruling BJP government dominated the outcome, say industry trackers.
  Experts say that foreign portfolio investors (FPIs) and other investors could now start investing in the India in the ne...

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='border:1px solid #cccccc;'>
   
  href='http://www.cainindia.org/news/3_2017/deals_of_the_daymergers_and_acquisitions.html?tstst=58ca57c3442e7&ntitle=Deals of the day-Mergers and acquisitions' style='text-decoration:none'>
  face='arial' color='#15c' size=2>Deals of the day-Mergers and acquisitions
 
face='arial' color='#333333' size='2'>(Adds GFH Financial, Euronet Worldwide, Air Methods, Glencore; Updates Toshiba, French Connection)
  March 14 (Reuters) - The following bids, mergers, acquisitions and disposals were reported by 1330 GMT on Tuesday:
  ** Sealed Air Corp is in exclusive talks to sell its cleaning and chemicals systems division, Diversey Care, to private equity firm Ba...

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='border:1px solid #cccccc;'>
   
  href='http://www.cainindia.org/news/3_2017/new_transfer_pricing_decree_a_step_closer_to_international_standards.html?tstst=58ca57c3442e7&ntitle=New transfer pricing decree: a step closer to international standards' style='text-decoration:none'>
  face='arial' color='#15c' size=2>New transfer pricing decree: a step closer to international standards
 
face='arial' color='#333333' size='2'>Decree 20 replaces the existing TP regulations (Circular No.66/2010/TT-BTC) and provides new compliance requirements in Vietnam.
  While Decree 20 is loosely based on Circular 66, it extends the interpretation of existing provisions and introduces additional concepts and principles from the Organization for Economic Cooperation and Development (OECD...

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  href='http://www.cainindia.org/news/3_2017/hp_budget_devoid_of_any_financial_prudence.html?tstst=58ca57c3442e7&ntitle=H.P. budget devoid of any financial prudence' style='text-decoration:none'>
  face='arial' color='#15c' size=2>H.P. budget devoid of any financial prudence
 
face='arial' color='#333333' size='2'>Initiating a discussion on the State budget for the year 2017-18, the leader of the opposition in Vidhan Sabha, Prem Kumar Dhumal, on Tuesday blamed the Virbhadra government for not identifying even a single factor for resource mobilisation and depending exclusively on borrowings and central allocations.
  The State, he said is dependent on central ...

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='border:1px solid #cccccc;'>
   
  href='http://www.cainindia.org/news/3_2017/_new_opening_manager_accounts_chartered_accountant.html?tstst=58ca57c3442e7&ntitle= New Opening Manager Accounts (chartered Accountant)' style='text-decoration:none'>
  face='arial' color='#15c' size=2> New Opening Manager Accounts (chartered Accountant)
 
face='arial' color='#333333' size='2'>Salary:INR 3,00,000 - 6,00,000 P.A.Industry:Electricals / SwitchgearsFunctional Area:Accounts , Finance , Tax , Company Secretary , AuditRole Category:AccountsRole:Accounts ManagerPG:CARecruiter Name:Mr Debi Prasad BiswalEmail Address:debi@macroresources.inWebsite:http://www.macroresources.inTelephone:7537008100...

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='border:1px solid #cccccc;'>
   
  href='http://www.cainindia.org/news/3_2017/_urgent_requirement_for_chartered_accountant.html?tstst=58ca57c3442e7&ntitle= Urgent Requirement For Chartered Accountant' style='text-decoration:none'>
  face='arial' color='#15c' size=2> Urgent Requirement For Chartered Accountant
 
face='arial' color='#333333' size='2'>Salary:INR 3,00,000 - 8,00,000 P.A.Industry:Chemicals / PetroChemical / Plastic / RubberFunctional Area:Accounts , Finance , Tax , Company Secretary , AuditRole Category:AccountsRole:Chartered AccountantPG:CAContact Company:Guljag Industries LimitedWebsite:http://www.guljag.com/...

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='border:1px solid #cccccc;'>
   
  href='http://www.cainindia.org/news/3_2017/cit_vs_uday_m_ghare_bombay_high_court.html?tstst=58ca57c3442e7&ntitle=CIT vs. Uday M. Ghare (Bombay High Court)' style='text-decoration:none'>
  face='arial' color='#15c' size=2>CIT vs. Uday M. Ghare (Bombay High Court)
 
face='arial' color='#333333' size='2'>S. 145: The average cost method of valuing inventories is an accepted method of valuation approved by the accounting standards issued by the ICAI. The AO is not entitled to disregard the method if the assessee has consistently followed the method
  The Assessing Officer sought to question the method of accounting only because the assessee has not be...

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  href='http://www.cainindia.org/news/3_2017/wadhwa_estate_developers_india_pvt_ltd_vs_acit_itat_mumbai.html?tstst=58ca57c3442e7&ntitle=Wadhwa Estate & Developers India Pvt. Ltd vs. ACIT (ITAT Mumbai)' style='text-decoration:none'>
  face='arial' color='#15c' size=2>Wadhwa Estate & Developers India Pvt. Ltd vs. ACIT (ITAT Mumbai)
 
face='arial' color='#333333' size='2'>S. 271(1)(c): Penalty cannot be levied if the omission to offer income, and the wrong claim of deduction, was by oversight and the auditors did not point it out. Also, the failure of the AO to specify the limb under which penalty u/s 271(1)(c) is imposed is a fatal error
  (i) Undisputedly, in the return of income assessee has failed to offer intere...

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  href='http://www.cainindia.org/news/3_2017/_cce_vs_vansum_industries_bombay_high_court.html?tstst=58ca57c3442e7&ntitle= CCE vs. Vansum Industries (Bombay High Court)' style='text-decoration:none'>
  face='arial' color='#15c' size=2> CCE vs. Vansum Industries (Bombay High Court)
 
face='arial' color='#333333' size='2'>The Commissioner and his officials are playing a blame game. To cover up their lapses and deficiencies, they turned around and blamed their Advocates .. We are sorry to say that this is not what was expected from the Commissioner of Service Tax. If the officers are unaware of legal procedures, then, they have to be in touch with their Advocates and...

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  href='http://www.cainindia.org/news/3_2017/anita_d_kanjani_vs_acit_itat_mumbai.html?tstst=58ca57c3442e7&ntitle=Anita D Kanjani vs. ACIT (ITAT Mumbai)' style='text-decoration:none'>
  face='arial' color='#15c' size=2>Anita D Kanjani vs. ACIT (ITAT Mumbai)
 
face='arial' color='#333333' size='2'>Capital gains: While s. 2(42A) uses the term "held", the other provisions use the terms "acquired", "purchased" and "owner". Accordingly, for considering whether an asset is a "long-term capital asset", the period of holding must be computed on a de facto basis. The letter of allottment, even though not "ownership", must be taken as the date of hol...

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  href='http://www.cainindia.org/news/3_2017/_ajay_enterprises_pvt_ltd_vs_assistant_commissioner_of_income_tax_tds_and_ors.html?tstst=58ca57c3442e7&ntitle= Ajay Enterprises Pvt. Ltd. Vs. Assistant Commissioner Of Income Tax (Tds) And Ors.' style='text-decoration:none'>
  face='arial' color='#15c' size=2> Ajay Enterprises Pvt. Ltd. Vs. Assistant Commissioner Of Income Tax (Tds) And Ors.
 
face='arial' color='#333333' size='2'>* IN THE HIGH COURT OF DELHI AT NEW DELHI
  Reserved on: 16.01.2017
  Decided on: 16.02.2017
   
  + W.P.(C) 8085/2014, C.M. APPL.18876/2014
  RAJESH PROJECTS (INDIA) PVT. LTD. ..... Petitioner
  Through : Sh. Prakash Kumar and Ms. Rashmi Sing...

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  color="#333333" size="2" face='arial'>For everyday detailed news update on ICAI, profession, latest judgments etc.; please visit at www.cainindia.org everyday.
 
  Best Regards,
  CAinINDIA Team
  www.cainindia.org
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