https://www.taxtmi.com/caselaws?id=325506 Calcutta HC denied Section 10(22A) exemption to an assessee incorporated for tax planning by the Apeejay group. The court found the assessee's dominant purpose was earning profit through interest income, not philanthropy. The assessee merely reimbursed medical costs to three tea companies rather than operating a hospital or institution for philanthropic purposes. Applying the Pulikkal Medical Foundation test, the court held no nexus existed between the income and any charitable activity. The institution accumulated income without engaging in any of the five specified activities under Section 10(22A), making it ineligible for exemption. en-us Fri, 18 Mar 2016 00:00:00 +0530 Tue, 08 Jul 2025 11:16:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=325506 Calcutta HC denied Section 10(22A) exemption to an assessee incorporated for tax planning by the Apeejay group. The court found the assessee's dominant purpose was earning profit through interest income, not philanthropy. The assessee merely reimbursed medical costs to three tea companies rather than operating a hospital or institution for philanthropic purposes. Applying the Pulikkal Medical Foundation test, the court held no nexus existed between the income and any charitable activity. The institution accumulated income without engaging in any of the five specified activities under Section 10(22A), making it ineligible for exemption. Case-Laws Income Tax Fri, 18 Mar 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=325506