Deduction u/s 80IB Upheld: Profit Comparison Between Charitable and Commercial Entities Deemed Inappropriate by CIT(A).

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....Disallowance of deduction u/s 80IB - Comparing profitability of two entities - as rightly noted by Ld. CIT(A), the profitability of the two entities could not be compared since MMHRC was a charitable entity having objects of Charity whereas MH was run on commercial basis. Pertinently, MH was a super specialty hospital having no competition. Therefore, to say that both the entities should have same profitability would not be a correct proposition - Thus the impugned order in granting full deduction u/s 80IB could not be faulted with. - AT....