TMI Blog2003 (3) TMI 74X X X X Extracts X X X X X X X X Extracts X X X X ..... der section 263 of the Income-tax Act for the assessment years 1985-86 to 1987-88 and in directing the Assessing Officer to restrict the exemption under section 10(22A) only to that income which is directly received from the medical institution under section 10(22A)?" - The question is answered in favour of the assessee and against the Revenue. - - - - - Dated:- 20-3-2003 - Judge(s) : R. JAYAS ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... under section 10(22) of the Act was nevertheless denied to the assessee by the Commissioner, who revised the order of the Assessing Officer who had granted such exemption by holding that a part of the income of the assessee was derived from sources other than the treatment of patients and, therefore, such income would disentitle the assessee to the benefit of section 10(22). The Tribunal, at the i ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... o of the decision of this court in CIT v. A.M.M. Arunachalam Educational Society [2000] 243 ITR 229 (Mad) is equally applicable to the income referred to in section 10(22A). "Any" income in that provision in effect means all income. The material requirement of section 10(22A) is that the hospital or institution referred to therein of the nature set out in that provision should exist solely for phi ..... X X X X Extracts X X X X X X X X Extracts X X X X
|
