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ITAT ruled that pharmacy division income of appellant hospital qualifies for exemption under Section 11(1) of Income Tax Act. The tribunal determined pharmacy operations were integral to hospital's dominant charitable purpose, not a separate business activity requiring distinct accounting under Section 11(4A). Following precedent in Jaslok Hospital case, ITAT found pharmacy services essential for both inpatient care and OPD treatment, directly supporting hospital's philanthropic objectives. The surplus from pharmacy operations was utilized for trust's charitable purposes. Accordingly, ITAT directed deletion of AO's addition, maintaining hospital's tax-exempt status for pharmacy division income.
ITAT ruled that pharmacy division income of appellant hospital qualifies for exemption under Section 11(1) of Income Tax Act. The tribunal determined pharmacy operations were integral to hospital's dominant charitable purpose, not a separate business activity requiring distinct accounting under Section 11(4A). Following precedent in Jaslok Hospital case, ITAT found pharmacy services essential for both inpatient care and OPD treatment, directly supporting hospital's philanthropic objectives. The surplus from pharmacy operations was utilized for trust's charitable purposes. Accordingly, ITAT directed deletion of AO's addition, maintaining hospital's tax-exempt status for pharmacy division income.
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