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The ITAT ruled in favor of the assessee trust operating a hospital, holding that income from its pharmacy operations qualifies for exemption under Section 11. The Tribunal determined that selling medicines, though on commercial basis, was incidental to the trust's charitable purpose of providing medical relief. Additional revenue streams including interest from fixed deposits, PCO receipts, canteen operations, nursing course fees, and rental income from premises were deemed incidental to the trust's dominant charitable purpose. The ITAT emphasized that these activities did not require separate accounting under Section 11(4A) as they were integral to achieving the main objective of providing educational/medical relief. The ruling established that incidental profit generation does not negate charitable status when the predominant purpose remains charitable in nature.
The ITAT ruled in favor of the assessee trust operating a hospital, holding that income from its pharmacy operations qualifies for exemption under Section 11. The Tribunal determined that selling medicines, though on commercial basis, was incidental to the trust's charitable purpose of providing medical relief. Additional revenue streams including interest from fixed deposits, PCO receipts, canteen operations, nursing course fees, and rental income from premises were deemed incidental to the trust's dominant charitable purpose. The ITAT emphasized that these activities did not require separate accounting under Section 11(4A) as they were integral to achieving the main objective of providing educational/medical relief. The ruling established that incidental profit generation does not negate charitable status when the predominant purpose remains charitable in nature.
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