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2013 (10) TMI 968 - AT - Income TaxBenefit to the concern falling u/s 13(3)(c) is right or not - Eligibility of exemption u/s 11 and 12 of the Income Tax Act - Assessee is a company registered u/s 25 of the Companies Act 1956 and also registered u/s 12AA of the Act - – Held that:- As per sub-section (6) a trust running an educational institution or a medical institution or a hospital shall not lose the benefit of exemption of any income other than the value of benefits of educational or medical facilities provided to the specified persons, solely on the ground that such benefits have been provided to specified persons. It should be noted that the sub-section covers,-(i) only those trusts running an educational institution or a medical institution or a hospital; (ii) the benefit extends only in respect of educational or medical facilities and not any other facility. In the present case, Assessee has entered transactions with the related concerns - Assessee is not an educational institution or a hospital or medical institution as it is not engaged in dispensing medical facility though it is engaged in running a blood bank - Assessee cannot be considered to be engaged in medical facilities so as to be entitled to exemption of income – Decided against the Assessee.
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