Hospital income exemption under section 10(22A) extends to all income where philanthropic and non-profit conditions are satisfied.

Section 10(22A) was construed to exempt "any income" of a hospital or institution existing solely for philanthropic purposes and not for profit, so the exemption was not confined to income directly received from the medical institution. The decisive condition was the charitable and non-profit character of the hospital, and once that was satisfied, the source of the income did not restrict the exemption. An order limiting the exemption only to income from the hospital's medical activities was therefore not sustainable.

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Issues: Whether the exemption under section 10(22A) of the Income-tax Act extends to all income of a hospital existing solely for philanthropic purposes and not for profit, and whether the revision under section 263 was justified in restricting the exemption only to income directly received from the medical institution.

Analysis: Section 10(22A) exempts "any income" of a hospital or other institution of the prescribed nature, and the expression "any" was construed to mean all income. The decisive requirement is that the institution must exist solely for philanthropic purposes and not for the purposes of profit. Since it was not disputed that the assessee-hospital satisfied that requirement, the source of the income did not limit the exemption.

Conclusion: The exemption covered all income received by the assessee from all sources, and the order restricting exemption was not sustainable.

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