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    <title>2026 (1) TMI 304 - ITAT RANCHI</title>
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    <description>Recognition under section 80G was refused because the assessee failed to show that its operations were genuinely charitable. The receipts were tied to a percentage of hospital turnover, the arrangement produced substantial surplus year after year, and the assessee did not demonstrate meaningful application of funds to purely charitable objects. The recorded finding that the assessee was not adhering to its stated objects, and that patient relief was negligible compared with income, remained unrebutted. The stated principle applied was that charitable activity cannot be treated as commercial activity for tax approval where the facts show a substantially commercial arrangement rather than genuine charity.</description>
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      <link>https://www.taxtmi.com/caselaws?id=784548</link>
      <description>Recognition under section 80G was refused because the assessee failed to show that its operations were genuinely charitable. The receipts were tied to a percentage of hospital turnover, the arrangement produced substantial surplus year after year, and the assessee did not demonstrate meaningful application of funds to purely charitable objects. The recorded finding that the assessee was not adhering to its stated objects, and that patient relief was negligible compared with income, remained unrebutted. The stated principle applied was that charitable activity cannot be treated as commercial activity for tax approval where the facts show a substantially commercial arrangement rather than genuine charity.</description>
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