Approval under section 10(23C)(via) depends on whether a...

Approval under section 10(23C)(via) depends on whether a hospital exists solely for philanthropic purposes and not for profit. Financial position should account for capital expenditure on medical equipment and facilities, actual application of funds, and depreciation, rather than excess receipts over revenue expenditure alone. Capital application and depreciation have distinct functions. Consultant-fee arrangements do not alone show profit distribution where retained sums pay for hospital facilities and services. Medical relief to paying patients may be philanthropic; no minimum ratio of free or concessional treatment is prescribed. Philanthropic character depends on objects, medical activities, application of income and assets, charitable-hospital obligations, and absence of unrelated commercial activity or private diversion.