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2018 (6) TMI 1513

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.... of society is, unless the context otherwise requires, "Health systems" includes the professional, technological, behavioural, social, economic, cultural and other subsystems whose interrelated action contribute to the health of the people. The objects of the assessee are as under: 3. 1.1 To promote and provide for study of health systems, health policy, health services management, health economics and medical sociology. 3.1. 2 To identify processes that can work to improve the health of the people. 3.1.3 To observe processes that work amongst the functionaries and beneficiaries of the health care delivery system. 3.1.4 To look for Locally viable solutions and innovations. 3.1.5 To assist in development and strengthening of li....

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....research training and consultancy in health and health care problems 3.1.19 To undertake teaching research and consultancy activities, intended to increase the effectiveness of health care services. 3.1.20 To undertake research on matters concerned with organized delivery and management of health services particularly resource allocation, development of appropriate planning methodologies, evaluation of health care and measurement of health activities. 3.1.21 To promote development of standards and quality systems in the health sector. 3.1.22 To promote adoption of cost effective regimen and appropriate technology in the health sector. 3.1.23 To carryout research and undertake consultancy educational and advisory services in c....

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.... under consideration by declaring "NI" income by claiming exemption u/s 11 of the Act. The return filed by the assessee was processed u/s 143(1) of the Act and thereafter, after following due procedure assessment was completed u/s 143(3) of the Act, while doing so, the AO denied the exemption u/s 11 as claimed by the assessee. For denial of exemption u/s 11, AO observed that during the year assessee provided services to Hyderabad Metro Water Supply and Sewerage Board (HMWSSB) towards water quality testing and incurred expenditure with reference to the services provided by it. According to AO, assessee has not incurred any expenditure relating to charitable activity for the cause of education, medical aid or relief to poor and even not incur....

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.... a nonprofitable organisation and therefore the receipts received by the assessee from testing of the water cannot be considered as commercial activity. Further, he submitted that assessee society is working for the health of general public, particu8larly, testing of the water and helping the HMWSSB and HMWSSB in turn, supplying good quality of water to the public at large in the city of Hyderabad. He, therefore, submitted that the activity carried out by the assessee is to be considered as a charitable activity. Referring to the page 134 of the paper book, ld. Counsel submitted that the receipts of the assessee are income from projects of Rs. 4,43,138/- and expenses of Rs. 4,36,500/-. He submitted that income from services was Rs. 50,98,13....

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....penses of Rs. 50,73,799/- during the year under consideration. The assessee also participated in various projects related to public health such as prevention of water borne deceases in urban slums of Hyderabad, risk assessment to establish health based targets for drinking water safety plans in Hyderabad, technical support for community health and medical provision impact of Nenates (Champion) Trial, air pollution and cause of deaths in Hyderabad, etc. The assessee has received income from projects of Rs. 4,43,138/- and expenses incurred Rs. 4,36,500/-. From the above, it is very clear that assessee society is not working for the profit and it is only collecting fees for the services rendered. In view of the above observations, we are of th....

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....participated in various research and consultation projects, education and training programmes etc. Therefore, the activity of the assessee is a charitable in nature, as the activity carried out by the assessee comes within the ambit of advancing of any other object of general public utility. In this connection, we refer to the provisions of section 2(15) of the Act, as under: "charitable purpose" includes relief of the poor, education, yoga, medical relief, preservation of environment (including watersheds, forests and wildlife) and preservation of monuments or places or objects of artistic or historic interest, and the advancement of any other object of general public utility. Provided that the advancement of any other object of gener....