Medical relief is treated as an independent charitable purpose,...

Medical relief is treated as an independent charitable purpose, so a modern hospital's scale, professional management, premium facilities, fees, substantial receipts or surplus does not by itself make its activities commercial. The key consideration is the continuing charitable object and application of income. Compliance with section 41AA of the Maharashtra Public Trusts Act and the IPF Scheme must be determined by the competent authorities under those laws, not independently assumed by the section 12AB authority. Expenditure incurred abroad for equipment and supplies used in hospitals in India is distinguished from applying income to charitable activities outside India. Retrospective cancellation requires fraud, misrepresentation or a defect in the original grant. Rejection under section 80G cannot rest solely on denial of section 12AB registration.

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