2025 (10) TMI 701

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....ce both the above appals were heard together therefore they are being disposed off by this consolidated order for the sake of convenience. 3. We shall firstly deal with the appeal of the Assessee in ITA No. 244/Chd/2025 for the Assessment Year 2025-26 wherein Ld. Counsel for the assessee submitted that the assessee's application seeking registration under section 12A(1)(ac)(iii) of the Act was rejected by the Ld. CIT (Exemptions) without issuing any show cause notice and without affording a reasonable opportunity of being heard before such rejection. It was also contended that such action is violative of the principles of natural justice. 4. Thus, against the order of the Ld CIT(E), the assessee is in appeal before us. 5. During th....

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....served that the assessee society shared its address with a hospital by the name Trinity Hospital. The perusal of the photographs as submitted by the assessee would show that the assessee's activities were basically been conducted by Trinity hospital. The assessee reflected expenses which were in the nature of conference expenses, donation expenses, medicine expenses, professional expenses salary / wages and tour and training expenses. For FY 2021-22, the assessee received donations from pharma companies, laboratories and medical instrument companies and registration fees from the doctors. The expenses were primarily to hold conferences from time to time or for sponsoring participation of its members in conferences held across India by payin....

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....other receipts. As against this, the major expenditure is on account of professional expenses. The other major expenses are in the nature of conference expenses, medicine expenses, advertisement and donations to other funds. No major expenditure is shown to have been incurred towards charitable activities. The perusal of donors would show that the major donors are medical centers, healthcare centers, pharma companies and labs etc. These donations have been used to conduct meetings / conferences. The perusal of photographs would show that the assessee is carrying out its activities under the banner of Trinity Hospital which, apparently, run as a commercial enterprises. On these facts, it could very well be concluded that there was direct nex....