An institution conducting hospital, medical college, education...

An institution conducting hospital, medical college, education and research activities for persons irrespective of religion, caste or creed should not be treated as purely religious merely because its governing documents contain an isolated reference to churchyards or burial grounds. The described Tribunal decision found no factual evidence of religious activities and held that selective reliance on one object clause, without examining financial statements or actual activities, was insufficient. It directed that the section 12AB registration be classified as religious-cum-charitable and that approval under section 80G(5) be granted, noting that the institution's medical and educational facilities were open to all sections of society and that there was no change in relevant facts.